2022 ? 001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: N/A Pass-Through Agency: Commonwealth of Massachusetts Executive Office of Administration and Finance Pass-Through Number(s): N/A Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Title 2 of the U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement, suspension, and debarment compliance requirements. The Town should have internal controls designed to ensure compliance with those provisions. Specifically, CFR Title 2, part 200.318 states that the non-Federal entity (the Town) must have and use documented procurement procedures which conform to the procurement standards identified in Title 2 CFR parts 200.317 through 200.327, as well as State and local regulations, for the acquisition of property or services required under a Federal award or subaward. Condition and Context: The Town did not maintain a current procurement policy that met the criteria outlined by Title 2 of the U.S. Code of Federal Regulations part 200.318. Questioned costs: Not applicable. Cause: Procurement policies and procedures are not documented in accordance with Title 2 of the U.S. Code of Federal Regulations. Effect: Noncompliance with federal compliance requirements occurred. Repeat Finding: No. Recommendation: We recommend the Town design and document a procurement policy in accordance with the compliance requirements outlined in Title 2 of the U.S. Code of Federal Regulations part 200.318. Views of responsible officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.
2022-002 Federal Agency: United States Department of Treasury Federal Program Name: COVID-19 ARPA Local Fiscal Recovery Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021, through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) 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 Town?s procurement standards included an incorrect threshold for small purchases as outlined in 2 CFR sections 200.318 through 200.326 ($25,000 versus $10,000). Questioned costs: None noted. Context: Although the Town did not have the correct threshold in place for small purchases in conformity with the federal uniform guidance criteria, the Town?s expenditures for ARPA were over the competitive bid threshold. Expenditures within the fiscal year were properly procured with competitive bids. Cause: The Town was unaware of the UG threshold requirements for small purchases. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Criteria: The County of Fremont should have processes in place to verify any entity(vendor) with which the County spends Federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. Condition: The Accounts Payable / Treasurer department did not have controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the County. Cause and Effect: There was not a control in place to ensure that vendors or contractors the County entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the County could enter into a contract with a suspended or debarred party. Repeat Finding: No Recommendation: We recommend that the Fremont County put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider adopt a policy on procurement for debarment.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00937 Pass-Through Agency: Bureau of Indian Affairs Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness 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 (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) 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 its procurement procedures to ensure compliance with federal regulations and guidelines and School policies were not in place. The School did not establish complete written procurement standards. In addition, the School did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. Lastly, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with Federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. During our review of purchasing, we noted the following: - For six of seven procurements over $25,000 reviewed, documentation demonstrating a vendor check for suspension and debarment was not retained. - Sealed bids were not performed in accordance with School policies. However, these purchases did not rise above the Simplified Acquisition Threshold. - For eight of 10 vendors reviewed with total expenditures below the Simplified Acquisition threshold, no documentation of quotes was maintained. - The School's policy did not include any language regarding quotes and thresholds. RECOMMENDATION The School should develop and implement policies and procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
FEDERAL PROCUREMENT Criteria: 2 CFR sections 200.318 through 200.327 govern procurement standards for federal programs. Per these standards, a non-federal entity (the city) must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Also, no employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition: The city does not have a formal, written conflict of interest policy or procurement manual as required by 2 CFR section 200.318. Cause: Responsible officials were unaware of the requirement. Effect: Noncompliance with federal procurement standards. Recommendation: The city should develop a formal procurement manual that contains all elements necessary to comply with 2 CFR sections 200.318 through 200.327. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.
FEDERAL PROCUREMENT Criteria: 2 CFR sections 200.318 through 200.327 govern procurement standards for federal programs. Per these standards, a non-federal entity (the city) must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Also, no employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition: The city does not have a formal, written conflict of interest policy or procurement manual as required by 2 CFR section 200.318. Cause: Responsible officials were unaware of the requirement. Effect: Noncompliance with federal procurement standards. Recommendation: The city should develop a formal procurement manual that contains all elements necessary to comply with 2 CFR sections 200.318 through 200.327. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.
FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. Criteria Institutions must follow the procurement standards set out at 2 C.F.R. ?? 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 C.F.R. part 200. 2 C.F.R. ? 200.318 through 200.326 Cause The Institution used its current policy for procurement that required various levels of internal management approval for purchases and didn?t have specific policies under 2 CFR 200. The institution did not verify that vendors were not disbarred prior to purchasing or making drawdowns. Effect There were no questioned costs associated with this finding as the Institution?s purchases claimed using HEERF were for allowable costs. Over $280,000 of the expenditures claimed would have been applicable for the small purchase method while all other purchases would have been applicable for the micro-purchase method. In certain instances, the Institution received approval from ED approving expenditures to be claimed using HEERF. In some cases, the Institution did receive bids from multiple vendors and researched what vendors were able to supply their needs. The individual responsible for overseeing the purchases determined that the price was fair and reasonable. Recommendation The Institution should update its procurement policies and procedures to ensure that all applicable aspects of the federal guidelines are documented and in accordance with the federal regulations. Views of Responsible Officials The Institution has reviewed the finding and concurs with the recommendation. As outlined in the Corrective Action Plan, the Institution has procedures in place to ensure compliance with the requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
2022-003 Noncompliance with Procurement Requirements Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CFDA No. 21.027) and Special Education (CFDA No.?s 84.027 and 84.173) Criteria: Recipients are required to comply with 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. The Board follows the Annotated Code of Maryland, the Education Article, and Board Policy DJB with respect to procurement. For purchases between $3,501 and $25,000, two written oral quotes must be acquired. Condition: Seven purchases between $3,501 and $25,000 were noted for which there was not documentation of two quotes or supporting documentation of single sourcing. Cause: The individuals in charge of purchasing did not document their procedures. Effect: The Board is not in compliance with the procurement requirements of the grant which could affect future funding. Repeat Finding: This finding was not a finding in FY21. Recommendation: We recommend the grants administrators communicate procurement requirements, including documentation requirements, to purchasing agents in order to avoid future misinterpretations and noncompliance. Views of Responsible Officials and Planned Corrective Action: The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.
FINDING 2022-001 SIGNIFICANT DEFICENCY and MATERIAL NONCOMPLIANCE Suspension and Debarment Condition: District did not verify that an entity with which it planned to enter into a covered transaction was not debarred, suspended or otherwise excluded as required by board policy and federal guidelines. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Criteria: Recommended Procedures Cause: During the course of the audit, we determined there exists a high reliance upon key positions of management to operate the procurement process without sufficient third-party review or involvement. Effect: The District entered into a covered transaction with Central Consolidated, Inc. without verifying they were not debarred, suspended or otherwise excluded. Recommendations: The Board of Directors, the Director and key positions of management should re-assess the current board policy and potentially add encompassing compensating controls. The Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding. See separate document for planned corrective actions.
Condition There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected two samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause CCI?s procurement policy was not updated to include the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
Finding No. 2022-002 Procurement Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 American Rescue Plan Act Local Fiscal Recovery Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021 through December 31, 2026 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria The Town must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326 and purchases were made that did not follow these requirements. Questioned Costs None noted. Context The Town did not have a policy in place in conformity with the federal Uniform Guidance criteria and purchases were made that did not follow these requirements. Effect With the absence of a compliant policy, the Town made purchases that did not follow federal Uniform Guidance procurement standards. Cause The Town was not aware of the details surrounding the Uniform Guidance procurement standards and its policy was not updated. Recommendation We recommend that the Town review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditors? recommendations. Corrective action will be taken to ensure the policy is updated and the correct procurement procedures are followed.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Procurement Questioned costs: $25,625 Condition?Contrary to federal regulations and County policies and procedures, the County inappropriately used sole source procurement for a contract paid for with federal program monies. Specifically, the Public Works Department, which initiated the sole source procurement, and the County?s former procurement officer who approved the sole source procurement inappropriately used a sole source procurement for a $25,625 contract for hauling dirt for the County Fair?s arena paid for with federal program monies, failing to ensure multiple sources for the service did not exist and to appropriately document the sole source justification in the contract file. This inappropriate sole source purchase comprised 3.6 percent of the program?s total federal award expenditures of $707,004 in fiscal year 2022. Effect?The County?s inappropriate use of a sole source procurement increased the County?s risk of not receiving the most advantageous price for the service purchased with federal monies. Therefore, the County may have inappropriately decreased federal program monies available for other program activities. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County?s current procurement officer reported that the former procurement officer is no longer employed with the County and, therefore, did not know why the County?s sole source procurement procedures were not followed, documented, and enforced. Criteria?Federal regulations permit noncompetitive purchases using federal program monies only in certain circumstances, such as when there is only a single source for purchasing goods/services, and require the County to establish and follow written policies and procedures that conform with the purchasing requirements of the federal Uniform Guidance (2 CFR ?200.318 and .320[c][2]). Further, County policies and procedures require sole source procurement to be avoided when possible and require the County procurement officer and departments to conduct a good-faith search for available sources and, if there is only one source for the goods or services being purchased, to document the determination for using sole source procurements prior to making such purchases and include it in the contract file (Gila County. [2019.] Procurement Policy, Section 8, Part C.). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Require the Public Works Department and procurement officer to follow County policies and procedures for determining and documenting each sole source procurement only after conducting a good-faith search for available sources and concluding there is only a single source and include it in the contract file. 2. Annually, train all County employees with purchasing responsibilities, including the Public Works Department and procurement officer, on the County?s policies and procedures for determining and documenting sole source procurements. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
2022-003 Procurement, Suspension and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20560 / 12060-SDE64370-20508 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. Condition: EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None Context: Although EASTCONN did not have a policy in place in conformity with the Federal Uniform Guidance criteria, EASTCONN did follow its own procedures as it relates to the contracts under the procurements applicable to EASTCONN?s major programs. Cause: EASTCONN did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that EASTCON review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with this finding.