Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (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: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is 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 noncompetitive 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. 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. (2) Proposals. 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. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Federal Agency: U.S. Department of Agriculture; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.559; 21.027 Federal Award Identification Number and Year: 214RI306N1099/214RI306N1199 - 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (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: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is 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 noncompetitive 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. 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. (2) Proposals. 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. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Towns purchasing policies within Coventry Public Schools do not include all elements as outlined in 2 CRF sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 4 of 4 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CRF sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Procurement and Suspension and Debarment compliance requirement was noted: • The County failed to properly document the expenditure for one (1) of the two (2) federal expenditures totaling $500,000. They did not execute a contract or award documents, and the invoice was not itemized. This expenditure had a questioned cost of $500,000. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant requirements and could result in a loss of federal funds. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 Internal Controls reads as follows: There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
FA 2022-002 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $474.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Background: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $2,764,279.02 were expended and reported on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Furthermore, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented, and applicable procurement compliance requirements were met. The following deficiencies were noted: The appropriate procurement method was not used for the dollar amount and conditions associated with one procurement transaction. The School District could not provide evidence that an adequate number of rate or price quotations was obtained from qualified sources for one small purchase expenditure reviewed. In addition, a sample of 40 covered transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and if suspension and debarment compliance requirements were met. The following exception was noted: For two expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Upon testing a sample of $13,307.47 in procurement transactions, known questioned costs of $474.00 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,363,942.86 in procurement transactions, we project the likely questioned costs to be approximately $48,623.00. Cause: The School District did not follow its policies and procedures that govern the procurement process for federal programs. Effect: The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address procurement compliance requirements could result in the expenditure of federal funds with unqualified vendors and the return of grant funds associated with these unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City’s procurement standards do not include 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 did not allow for 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 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. The City will update the purchasing policy to include the CFR requirements.
Department of Labor, YouthBuild Federal Financial Assistance Listing Number # 17.274, 2020-2023 Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected. For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected. Repeat Finding from Prior Years: Yes Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections. Views of Responsible Officials: Management is in agreement with this finding.