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.
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.
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.
Identification of federal program: US DEPARTMENT OF EDUCATION, passed through the Indiana Department of Education, Charter Schools Program 84.282A Criteria : In accordance with CFR 200.318(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. In addition, in accordance with CFR 200.318(a) the non- federal entity must have and use documented procurement procedures consistent with federal procurement standards. Condition: Expenditures tested that met the small purchase threshold (purchases with a cost between $10,000 and $250,000) did not have documentation detailing the history of procurement. Cause : The School does not have procurement policies that follow federal guidelines, specifically 2 CFR 200.320 Methods of procurement to be followed. Effect : Property and equipment additions made using federal funds during the year did not have appropriate a support showing procurement policies were followed. Questioned costs: $83,864 Context: Two out of two purchases tested for procurement did not follow federal procurement methods. Recommendation : We recommend that the School institute procurement policies whereby acquisitions follow appropriate procurement steps as required by 2 CRF 200.350 and documentation of procurement decisions is maintained. View of responsible officials : See attached corrective action plan
U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Procurement Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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. The Organization is required to create a written procurement, suspension, and debarment policy that complies with applicable federal requirements and to follow this policy when procuring goods and services. The Organization is also required to retain documentation supporting performance of a price analysis and open competition. Condition: The Organization’s procurement policy does not contain all provisions required by Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a price analysis over the transactions tested. Cause: The Organization has limited staffing and did not have proper controls in place relating to review of the procurement policy. Effect: The Organization did not ensure that the procurement policy was complete and accurate. Questioned Costs: None reported. Context: A nonstatistical sample of 4 out of 9 procurement transactions were selected for testing, which accounted for $175,792 of $370,234 qualified expenditures.Repeat Finding from Prior Years: No Recommendation: We recommend the Organization follow control processes implemented which includes updating the procurement policy and documenting the performance of required procurement procedures. Views of Responsible Officials: Management agrees with the finding.
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: USDA School Breakfast Program and National School Lunch Program FAL Number: 10.553 and 10.555 Passthrough: New Mexico Public Education Department Award Year: 2022 Criteria: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, sub awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. §200.317 Procurements by states. When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. The state will comply with §200.322 Procurement of recovered materials and ensure that every purchase order or other contract includes any clauses required by section §200.326 Contract provisions. All other non-Federal entities, including sub recipients of a state, will follow §200.318 General procurement standards through 200.326 Contract provisions. §200.318 General procurement standards. (a) The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. (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. APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” https://www.sam.gov/portal/public/SAM/ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: During our testing of single audit disbursements, we identified five vendors which would meet the requirement of verifying that the vendor was not suspended or debarred or otherwise excluded from receiving the contract which was funded through Federal dollars. The vendor received single payments in excess of $25,000 from the District from Federal grant sources. The vendors are not currently suspended or debarred from receiving Federal contracts; however, the District did not have proper internal controls in place to verify this prior to the purchase. Questioned Costs: None Cause: District personnel did not verify that vendors which meet the $25,000 thresholds are not suspended, debarred, or otherwise excluded from participating in contracts funded through Federal awards due to a misunderstanding of staff personnel regarding this requirement. Effect: The District is not in compliance with Federal regulations related to the grant and could put funding in jeopardy or require the District to reimburse the program for improper grant distributions.Auditor’s Recommendation: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors are not suspended or debarred. The District may have the vendor provide an annual certification that it is not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive but also effective in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for finding: The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. • Timeline for completion of corrective action plan: July 1, 2023 • Employee position(s) responsible for meeting the timeline: Grants Specialists, CPO, Finance Specialist, Purchasing Specialist, Federal Grants Coordinator, Federal Grants Specialist
2022 ? 001: Procurement Federal Agency: U.S. Department of Justice Federal Program Name: Crime Victim Services Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Department of Public Safety Office of Justice Programs Pass-Through Number(s): A-CVS-2020-CADA-00030 Award Period: October 1, 2019 through September 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR section 200.318(a) - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition: The Organization's procurement policy is limited in terms of documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Questioned costs: None Context: We noted the Organization?s current policy states ?expenditures in excess of $5,000 for the purchase of a single item is required to have bids from three suppliers if possible.? However, the federal guidelines have increased those same thresholds to $10,000 for quotations and $250,000 for sealed bids. The policy is silent as to when sealed bids are required. Cause: The process of ensuring grant requirements are understood. Effect: Procurement transactions may be not be compliant with Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Organization update the purchasing section of its current Fiscal Policies and Procedures manual. The updated procedures should at a minimum address general procurement standards. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001: Procurement Federal Agency: U.S. Department of Justice Federal Program Name: Crime Victim Services Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Department of Public Safety Office of Justice Programs Pass-Through Number(s): A-CVS-2020-CADA-00030 Award Period: October 1, 2019 through September 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR section 200.318(a) - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition: The Organization's procurement policy is limited in terms of documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Questioned costs: None Context: We noted the Organization?s current policy states ?expenditures in excess of $5,000 for the purchase of a single item is required to have bids from three suppliers if possible.? However, the federal guidelines have increased those same thresholds to $10,000 for quotations and $250,000 for sealed bids. The policy is silent as to when sealed bids are required. Cause: The process of ensuring grant requirements are understood. Effect: Procurement transactions may be not be compliant with Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Organization update the purchasing section of its current Fiscal Policies and Procedures manual. The updated procedures should at a minimum address general procurement standards. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 001 ? Child Nutrition Cluster ? Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 2020-2021 and FY 2021-2022 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: FY 2020-2021, FY 2021-2022 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: During our testing, we noted the Westfield-Washington Schools did not have a policy to review vendors to ensure they were not suspended or debarred. Questioned costs: None Context: Although Westfield Washington School Corporation did not have a policy in place in conformity with the federal Uniform Guidance criteria, the entities with which the Westfield Washington School Corporation made purchases from were not suspended or debarred. Cause: Improper understanding and implementation of federal Uniform Guidance policies. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: Yes Recommendation: We recommend the Westfield-Washington Schools increased training for those individuals involved in procurement and contract approval to ensure all federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contracts. View of Responsible Officials: There is no disagreement with the audit finding.
FA 2022-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425U210012 (Year: 2021) Questioned Costs: $61,000.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $2,583,527.47 were expended and reported on the Atkinson 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. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that ?retention? bonuses were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain in the service of the School District for a stated period of time was not reflected within the associated contract. Therefore, expenditures totaling $61,000.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $61,000.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425U210012 (Year: 2021) Questioned Costs: $61,000.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $2,583,527.47 were expended and reported on the Atkinson 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. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that ?retention? bonuses were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain in the service of the School District for a stated period of time was not reflected within the associated contract. Therefore, expenditures totaling $61,000.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $61,000.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Section III. Findings and Questioned Costs for Federal Awards 2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: This is a repeat audit finding from the prior year audit and was reported as finding 2021-002. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. View of Responsible Officials: The Law School agrees with the finding and have adopted an appropriate procurement policy as of June 15, 2022. Awards, including sole source awards will be adequately documented.