2024 - 007: Procurement Federal Agency: U.S. Department of Education Federal Program Title: Special Education Cluster ALN: 84.027 and 84.173 Federal Award Identification Numbers and Year: H027A230087 & H173A230086, 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A230087 & H173A230086 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: The District should have controls in place to ensure compliance per the requirements of 2 CFR §200.303. 2 CFR section 200.318(i) requires the District to maintain records sufficient to detail the history of procurement. These records should 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. Condition: The District did not perform the required control over procurement procedures over covered transactions in the special education program in 2024. Questioned Costs: $19,317 Context: Of the covered transactions tested, it was noted that the District did not perform the required control over procurement on 3 of 3 items tested for the special education program. Cause: District did not retain the proper documentation for the procurement method utilized. Effect: Without proper controls in place, there is a higher likelihood that District could not be in compliance with federal procurement requirements. Repeat Finding: No Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. View of Responsible Official: There is no disagreement with the audit finding.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §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. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §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. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §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. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.