FINDING 2024-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024, FY23/FY24 Pass-Through Entity: Indiana Department of Education 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 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: Micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchases threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. There were no internal controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was no review or oversight process performed. Suspension and Debarment There were no internal controls in place to ensure that the School Corporation complied with the suspension and debarment requirements. The School Corporation did not verify that the two vendors were not suspended or debarred. They did not have a contract with the vendors that included the suspension and debarment clause, did not collect a certification from the vendors, and did not check the Sam.gov website to verify that vendors were not suspended or debarred. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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." INDIANA STATE BOARD OF ACCOUNTS 18 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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.gov Exclusions, or (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was not a review or oversight performed. The School Corporation was unaware of the requirement to provide documentation to show that a verification was done to determine that the two vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could have used a vendor that charged more than the lowest quote for small purchases or could have entered into transaction with vendors that were excluded from participating in federal transactions. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024, FY23/FY24 Pass-Through Entity: Indiana Department of Education 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 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: Micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchases threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. There were no internal controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was no review or oversight process performed. Suspension and Debarment There were no internal controls in place to ensure that the School Corporation complied with the suspension and debarment requirements. The School Corporation did not verify that the two vendors were not suspended or debarred. They did not have a contract with the vendors that included the suspension and debarment clause, did not collect a certification from the vendors, and did not check the Sam.gov website to verify that vendors were not suspended or debarred. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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." INDIANA STATE BOARD OF ACCOUNTS 18 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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.gov Exclusions, or (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was not a review or oversight performed. The School Corporation was unaware of the requirement to provide documentation to show that a verification was done to determine that the two vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could have used a vendor that charged more than the lowest quote for small purchases or could have entered into transaction with vendors that were excluded from participating in federal transactions. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024, FY23/FY24 Pass-Through Entity: Indiana Department of Education 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 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: Micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchases threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. There were no internal controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was no review or oversight process performed. Suspension and Debarment There were no internal controls in place to ensure that the School Corporation complied with the suspension and debarment requirements. The School Corporation did not verify that the two vendors were not suspended or debarred. They did not have a contract with the vendors that included the suspension and debarment clause, did not collect a certification from the vendors, and did not check the Sam.gov website to verify that vendors were not suspended or debarred. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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." INDIANA STATE BOARD OF ACCOUNTS 18 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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.gov Exclusions, or (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was not a review or oversight performed. The School Corporation was unaware of the requirement to provide documentation to show that a verification was done to determine that the two vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could have used a vendor that charged more than the lowest quote for small purchases or could have entered into transaction with vendors that were excluded from participating in federal transactions. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024, FY23/FY24 Pass-Through Entity: Indiana Department of Education 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 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: Micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchases threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. There were no internal controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was no review or oversight process performed. Suspension and Debarment There were no internal controls in place to ensure that the School Corporation complied with the suspension and debarment requirements. The School Corporation did not verify that the two vendors were not suspended or debarred. They did not have a contract with the vendors that included the suspension and debarment clause, did not collect a certification from the vendors, and did not check the Sam.gov website to verify that vendors were not suspended or debarred. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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." INDIANA STATE BOARD OF ACCOUNTS 18 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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.gov Exclusions, or (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but there was not a review or oversight performed. The School Corporation was unaware of the requirement to provide documentation to show that a verification was done to determine that the two vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could have used a vendor that charged more than the lowest quote for small purchases or could have entered into transaction with vendors that were excluded from participating in federal transactions. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 SOUTH VERMILLION COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; Special Education Preschool Grants Assistance Listings Numbers: 84.027X; 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.313(d) states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 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. . . .” (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . .” (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 2 CFR 180.300 states: “When you enter into a covered transaction with another person as 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.” Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold. Therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. When the purchase value exceeds the micro-purchase threshold but is less than the simplified acquisition threshold, a small purchase occurs. Small purchases require documented full and open competition or a documented rationale for limited competition. For fiscal year 2023, the Cooperative had one vendor, with disbursements totaling $379,313, which exceeded the SAT threshold of $150,000. The Cooperative did not obtain sealed bids or competitive proposals nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For fiscal year 2023, the Cooperative had one vendor with disbursements in the amount of $55,374, which were less than the SAT threshold of $150,000, but exceeded the $50,000 micro-purchase threshold and was selected for testing. The Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For fiscal year 2024, three vendors with disbursements totaling $175,125, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold and were selected for testing. The Cooperative did not obtain price or rate quotes for two of the three vendors and there was no documentation detailing the history of the procurement, which must include the reason for the procurement method used. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to contracts, for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the Cooperative in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed there were not any documented controls or procedures. Nine covered transactions were identified. The covered transactions, totaling $803,836, were selected for testing. The Cooperative did not verify the suspension and debarment status of the tested vendors prior to payment. The lack of internal controls and noncompliance were systemic throughout the audit period. Cause: The Cooperative noted that ARP portion of the Special Education grant was new for the 2022-2023 and 2023-2024 school years. The ARP funding gave opportunity for types of expenditures that do not typically get expensed using Special Education funding. The transactions noted within the Condition and Context were from the ARP portion of the grant, which provided property or services that exceeded the micro-purchase threshold. Management of the Cooperative was unaware of the procurement requirements when property or services exceed the micro-purchase threshold. In addition, management of the Cooperative was unaware of the Suspension and Debarment requirements when a covered transaction is expected to equal or exceed $25,000. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Without following the required methods for procurement, the Cooperative could be overpaying for services. Unverified vendors to whom payments equal to or in excess of $25,000 could be suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the Cooperative. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Identification as a repeat finding: No. Recommendation: We recommended that the Cooperative’s management design and implement a system of internal controls related to procurement and suspension and debarment procedures to ensure procurement requirements are met and to ensure entities are neither suspended nor debarred, or otherwise excluded or disqualified prior to entering into any covered transactions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; Special Education Preschool Grants Assistance Listings Numbers: 84.027X; 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.313(d) states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 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. . . .” (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . .” (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 2 CFR 180.300 states: “When you enter into a covered transaction with another person as 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.” Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold. Therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. When the purchase value exceeds the micro-purchase threshold but is less than the simplified acquisition threshold, a small purchase occurs. Small purchases require documented full and open competition or a documented rationale for limited competition. For fiscal year 2023, the Cooperative had one vendor, with disbursements totaling $379,313, which exceeded the SAT threshold of $150,000. The Cooperative did not obtain sealed bids or competitive proposals nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For fiscal year 2023, the Cooperative had one vendor with disbursements in the amount of $55,374, which were less than the SAT threshold of $150,000, but exceeded the $50,000 micro-purchase threshold and was selected for testing. The Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For fiscal year 2024, three vendors with disbursements totaling $175,125, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold and were selected for testing. The Cooperative did not obtain price or rate quotes for two of the three vendors and there was no documentation detailing the history of the procurement, which must include the reason for the procurement method used. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to contracts, for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the Cooperative in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed there were not any documented controls or procedures. Nine covered transactions were identified. The covered transactions, totaling $803,836, were selected for testing. The Cooperative did not verify the suspension and debarment status of the tested vendors prior to payment. The lack of internal controls and noncompliance were systemic throughout the audit period. Cause: The Cooperative noted that ARP portion of the Special Education grant was new for the 2022-2023 and 2023-2024 school years. The ARP funding gave opportunity for types of expenditures that do not typically get expensed using Special Education funding. The transactions noted within the Condition and Context were from the ARP portion of the grant, which provided property or services that exceeded the micro-purchase threshold. Management of the Cooperative was unaware of the procurement requirements when property or services exceed the micro-purchase threshold. In addition, management of the Cooperative was unaware of the Suspension and Debarment requirements when a covered transaction is expected to equal or exceed $25,000. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Without following the required methods for procurement, the Cooperative could be overpaying for services. Unverified vendors to whom payments equal to or in excess of $25,000 could be suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the Cooperative. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Identification as a repeat finding: No. Recommendation: We recommended that the Cooperative’s management design and implement a system of internal controls related to procurement and suspension and debarment procedures to ensure procurement requirements are met and to ensure entities are neither suspended nor debarred, or otherwise excluded or disqualified prior to entering into any covered transactions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2024-072: Strengthen Controls over Procurement Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Procurement and Suspension and Debarment - 2 CFR § 200.317 Known Questioned Costs: $0 Epidemiology is not compiling and retaining a comprehensive contract listing for all procured and active contracts funded by the ELC federal grant program. Management was unable to provide the comprehensive contract listing due to not properly maintaining the documentation. Title 2 CFR § 200.317 governs procurements by states and requires that “when procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds.” Department of General Services Agency Procurement and Surplus Property Manual (APSPM) - Section 10.3 requires agencies to maintain a complete file in one place for each purchase transaction. It states that the file must contain, at a minimum, as applicable, the description of requirements, sources solicited, a copy of the Virginia Business Opportunities receipt, cancellation notices, the method of evaluation and award, a signed copy of the contract or purchase order, contractor performance report submitted by the administrator, modifications or change orders, vendor complaint forms, cure letters, usage data such as release or obligation registers, and any other actions relating to the procurement. In addition, APSPM Annex 10-A, which is a Post Award Administration Checklist, requires the agency to list the contract on the agency’s master contract list or schedule to include period of performance and any renewal option(s) to allow for the planning of renewal or rebidding actions. Health's individual offices or Local Health Districts (LHD) complete procurements for the ELC federal grant program up to $100,000, with procurements over $10,000 and up to $100,000 being solicited through a “quick quote.” Health’s Office of Procurement and General Services handles complex procurements. Since Health has 35 LHDs, the absence of a comprehensive contract listing increases the risk of a contract being established by an LHD that goes unnoticed by Epidemiology. Due to limited staff and the number of health offices and LHDs involved in the procurement process, Epidemiology was unable to provide a comprehensive contract listing. By not maintaining proper documentation and support, Health is unable to ensure the effectiveness of internal controls. Furthermore, it is difficult to substantiate the legitimacy of the procurement transaction, increasing the risk of unauthorized transactions, which also increases the potential for questioned costs. Health’s management should develop a policy requiring the compilation of comprehensive contract listings and communicate the policy to the applicable offices and districts. Health’s management should also ensure that the applicable offices and districts involved have adequate staffing and training on contract procurement and the need to maintain adequate documentation for all procurements. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-072: Strengthen Controls over Procurement Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Procurement and Suspension and Debarment - 2 CFR § 200.317 Known Questioned Costs: $0 Epidemiology is not compiling and retaining a comprehensive contract listing for all procured and active contracts funded by the ELC federal grant program. Management was unable to provide the comprehensive contract listing due to not properly maintaining the documentation. Title 2 CFR § 200.317 governs procurements by states and requires that “when procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds.” Department of General Services Agency Procurement and Surplus Property Manual (APSPM) - Section 10.3 requires agencies to maintain a complete file in one place for each purchase transaction. It states that the file must contain, at a minimum, as applicable, the description of requirements, sources solicited, a copy of the Virginia Business Opportunities receipt, cancellation notices, the method of evaluation and award, a signed copy of the contract or purchase order, contractor performance report submitted by the administrator, modifications or change orders, vendor complaint forms, cure letters, usage data such as release or obligation registers, and any other actions relating to the procurement. In addition, APSPM Annex 10-A, which is a Post Award Administration Checklist, requires the agency to list the contract on the agency’s master contract list or schedule to include period of performance and any renewal option(s) to allow for the planning of renewal or rebidding actions. Health's individual offices or Local Health Districts (LHD) complete procurements for the ELC federal grant program up to $100,000, with procurements over $10,000 and up to $100,000 being solicited through a “quick quote.” Health’s Office of Procurement and General Services handles complex procurements. Since Health has 35 LHDs, the absence of a comprehensive contract listing increases the risk of a contract being established by an LHD that goes unnoticed by Epidemiology. Due to limited staff and the number of health offices and LHDs involved in the procurement process, Epidemiology was unable to provide a comprehensive contract listing. By not maintaining proper documentation and support, Health is unable to ensure the effectiveness of internal controls. Furthermore, it is difficult to substantiate the legitimacy of the procurement transaction, increasing the risk of unauthorized transactions, which also increases the potential for questioned costs. Health’s management should develop a policy requiring the compilation of comprehensive contract listings and communicate the policy to the applicable offices and districts. Health’s management should also ensure that the applicable offices and districts involved have adequate staffing and training on contract procurement and the need to maintain adequate documentation for all procurements. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-072: Strengthen Controls over Procurement Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Procurement and Suspension and Debarment - 2 CFR § 200.317 Known Questioned Costs: $0 Epidemiology is not compiling and retaining a comprehensive contract listing for all procured and active contracts funded by the ELC federal grant program. Management was unable to provide the comprehensive contract listing due to not properly maintaining the documentation. Title 2 CFR § 200.317 governs procurements by states and requires that “when procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds.” Department of General Services Agency Procurement and Surplus Property Manual (APSPM) - Section 10.3 requires agencies to maintain a complete file in one place for each purchase transaction. It states that the file must contain, at a minimum, as applicable, the description of requirements, sources solicited, a copy of the Virginia Business Opportunities receipt, cancellation notices, the method of evaluation and award, a signed copy of the contract or purchase order, contractor performance report submitted by the administrator, modifications or change orders, vendor complaint forms, cure letters, usage data such as release or obligation registers, and any other actions relating to the procurement. In addition, APSPM Annex 10-A, which is a Post Award Administration Checklist, requires the agency to list the contract on the agency’s master contract list or schedule to include period of performance and any renewal option(s) to allow for the planning of renewal or rebidding actions. Health's individual offices or Local Health Districts (LHD) complete procurements for the ELC federal grant program up to $100,000, with procurements over $10,000 and up to $100,000 being solicited through a “quick quote.” Health’s Office of Procurement and General Services handles complex procurements. Since Health has 35 LHDs, the absence of a comprehensive contract listing increases the risk of a contract being established by an LHD that goes unnoticed by Epidemiology. Due to limited staff and the number of health offices and LHDs involved in the procurement process, Epidemiology was unable to provide a comprehensive contract listing. By not maintaining proper documentation and support, Health is unable to ensure the effectiveness of internal controls. Furthermore, it is difficult to substantiate the legitimacy of the procurement transaction, increasing the risk of unauthorized transactions, which also increases the potential for questioned costs. Health’s management should develop a policy requiring the compilation of comprehensive contract listings and communicate the policy to the applicable offices and districts. Health’s management should also ensure that the applicable offices and districts involved have adequate staffing and training on contract procurement and the need to maintain adequate documentation for all procurements. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-053-PN01, 22611-053-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 23 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the South La Porte County Special Education Cooperative (Cooperative). The Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Procurement - Small Purchase When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000; however, the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5-22-8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent with all five vendors was $292,806. The lack of internal controls and noncompliance was isolated to 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Six vendors paid from the grant funds were identified as being covered transactions during the audit period. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 and were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for 2023 and 2024, respectively. For all six vendors, the Cooperative did not verify the vendors' suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to the 22611-053-PN01 and 22611-053-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.320 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.gov 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 Cooperative noted they were unaware of the procurement requirements of expenditures within the Small Purchase Threshold and for suspension and debarment. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. INDIANA STATE BOARD OF ACCOUNTS 25 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative cannot ensure the vendors paid with federal award funds are procured using the required methods and are not suspended or debarred from receiving federal funds. Without following the required methods for procurement and suspension and debarment, the Cooperative could be overpaying for services or could be paying vendors who are precluded from receiving federal funds. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require that appropriate procurement methods are used for vendors that are within the Small Purchase Threshold and to ensure vendors are not suspended or debarred. 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.
FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-053-PN01, 22611-053-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 23 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the South La Porte County Special Education Cooperative (Cooperative). The Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Procurement - Small Purchase When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000; however, the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5-22-8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent with all five vendors was $292,806. The lack of internal controls and noncompliance was isolated to 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Six vendors paid from the grant funds were identified as being covered transactions during the audit period. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 and were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for 2023 and 2024, respectively. For all six vendors, the Cooperative did not verify the vendors' suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to the 22611-053-PN01 and 22611-053-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.320 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.gov 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 Cooperative noted they were unaware of the procurement requirements of expenditures within the Small Purchase Threshold and for suspension and debarment. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. INDIANA STATE BOARD OF ACCOUNTS 25 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative cannot ensure the vendors paid with federal award funds are procured using the required methods and are not suspended or debarred from receiving federal funds. Without following the required methods for procurement and suspension and debarment, the Cooperative could be overpaying for services or could be paying vendors who are precluded from receiving federal funds. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require that appropriate procurement methods are used for vendors that are within the Small Purchase Threshold and to ensure vendors are not suspended or debarred. 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.
FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-053-PN01, 22611-053-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 23 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the South La Porte County Special Education Cooperative (Cooperative). The Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Procurement - Small Purchase When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000; however, the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5-22-8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent with all five vendors was $292,806. The lack of internal controls and noncompliance was isolated to 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Six vendors paid from the grant funds were identified as being covered transactions during the audit period. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 and were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for 2023 and 2024, respectively. For all six vendors, the Cooperative did not verify the vendors' suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to the 22611-053-PN01 and 22611-053-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.320 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.gov 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 Cooperative noted they were unaware of the procurement requirements of expenditures within the Small Purchase Threshold and for suspension and debarment. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. INDIANA STATE BOARD OF ACCOUNTS 25 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative cannot ensure the vendors paid with federal award funds are procured using the required methods and are not suspended or debarred from receiving federal funds. Without following the required methods for procurement and suspension and debarment, the Cooperative could be overpaying for services or could be paying vendors who are precluded from receiving federal funds. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require that appropriate procurement methods are used for vendors that are within the Small Purchase Threshold and to ensure vendors are not suspended or debarred. 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.
FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-053-PN01, 22611-053-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 23 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the South La Porte County Special Education Cooperative (Cooperative). The Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Procurement - Small Purchase When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000; however, the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5-22-8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent with all five vendors was $292,806. The lack of internal controls and noncompliance was isolated to 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Six vendors paid from the grant funds were identified as being covered transactions during the audit period. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 and were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for 2023 and 2024, respectively. For all six vendors, the Cooperative did not verify the vendors' suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to the 22611-053-PN01 and 22611-053-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.320 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.gov 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 Cooperative noted they were unaware of the procurement requirements of expenditures within the Small Purchase Threshold and for suspension and debarment. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. INDIANA STATE BOARD OF ACCOUNTS 25 LA PORTE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the Cooperative cannot ensure the vendors paid with federal award funds are procured using the required methods and are not suspended or debarred from receiving federal funds. Without following the required methods for procurement and suspension and debarment, the Cooperative could be overpaying for services or could be paying vendors who are precluded from receiving federal funds. Questioned Costs There were no questioned costs identified. Recommendation Management of the Cooperative should develop written policies and procedures which would require that appropriate procurement methods are used for vendors that are within the Small Purchase Threshold and to ensure vendors are not suspended or debarred. 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.
FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years(or Other Identifying Numbers): 22611-043-ARP, 23611-043-PN01, 24611-043-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000; however, Indiana Code 5-22-8 has a more restrictive threshold, and, therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with procurement requirements. The Cooperative did not have procedures in place to ensure compliance with procurements in excess of the SAT threshold. During 2023-2024, the Cooperative had three vendors which exceeded the SAT and all three vendors were tested. The Cooperative did not obtain sealed bids or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total dollar amount spent with all three vendors was $1,417,349. INDIANA STATE BOARD OF ACCOUNTS 17 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were systemic issues limited to 2023-2024. 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 200.320 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: . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or costreimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." INDIANA STATE BOARD OF ACCOUNTS 18 HANOVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The Cooperative noted they were unaware of the procurement requirements of expenditures exceeding the Simplified Acquisition Threshold. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the vendors paid with federal award funds by the Cooperative are procured using the required methods. Without following the required methods for procurement, the Cooperative could be overpaying for services. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require that appropriate procurement methods are used by the Cooperative for vendors that exceed the Simplified Acquisition Threshold. Appropriate documentation should be maintained to ensure the procurement methods are being followed and compliance with procurement methods are being followed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.