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.
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.
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.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 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 sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? 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)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 section 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 for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 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 sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? 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)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 section 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 for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement Federal Award Identification Number and Year: MD0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2CFR ? 200.318(a), non-Federal entities 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. Questioned Costs: None Condition/Context: The Town?s procurement policy for federal expenditures is not in accordance with ?? 200.317 through 200.327. Therefore, for one of three vendors tested, proper procurement processes of obtaining price or rate quotations from an adequate number of qualified sources was not followed. Cause: The Town?s policies and procedures did not require proper federal procurement requirements to be followed prior to paying a vendor with Federal grant funds. Effect: Funds were disbursed to vendors without following proper federal procurement requirements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Town establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Views of responsible officials: Management agrees with the finding.
2022-001 Department of Education CFDA # 84.425F ? Education Stabilization Fund - Institutional Award Number P425F202362 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls 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 depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Cause: Based on limited federal funding previously received that would require a written policy and lack of awareness or understanding of all of the specific requirements under the Uniform Guidance specific to written policy requirements over procurement, suspension and debarment. Effect: A lack of established controls increases the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower-tier entities. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 3 vendors out of 5 vendors that meet thresholds required for procurement and suspension debarment testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the University implement a procurement policy as required under Uniform Guidance with the required components that can be used if future federal assistance is received. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-003: Procurement & Suspension and Debarment Material weakness in internal control over Procurement & Suspension and Debarment and Noncompliance U.S. Department of Treasury; Coronavirus State Local Fiscal Recovery Funds (SLFRF) passed through Fresno County. AL No. 21.027. Questioned Cost: Not applicable How the Questioned Cost was Computed: Not applicable Condition: C&M identified that the FCFPD did not have adequate written policies and did not maintain a written code of standard selection procedures for procurement transactions that included all the requirements of the Uniform Guidance. C&M identified a lack of adequate knowledge and experience of key procurement managers in light of responsibilities for procurements for Federal awards. In addition, the costs charged to the program included fuel cost incurred by FCFPD. The fuel cost had been procured from a couple vendors. The FCFPD stated the selection of these vendors was based on past experience and was not able to provide C&M with support of a noncompetitive procurement process that complies with 2 CFR 200 standards. Also, there was no evidence that FCFPD verified that vendors were not suspended or debarred or otherwise excluded from participating in the transactions before entering into the transaction with them. Criteria: The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, section 318(i) (Uniform Guidance) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. The records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contractor type, contractor selection or rejection, and the basis for the contract price. In addition, the Uniform Guidance, 2 CFR Part 200, section 200.118 states that the non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 and must use their own documented procurement procedures that must conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The FCFPD?s procurement policy is limited to establishing a guideline on spending and purchasing authority limits. There was a lack of understanding of federal laws and regulations relating to this requirement. Management did not have an understanding of the requirements for procurement and suspension and debarment. Effect: Procurements were made following a noncompetitive process that were not adequately documented and FCFPD could enter into transactions with vendors that are suspended of debarred. Costs charged to the Program could be disallowed. Recommendation: C&M recommends the FCFPD establish written procurement policies and procedures as required by the Uniform Guidance. The FCFPD should consider implementation of the following internal controls: 1. Review the Uniform Guidance and update the current policies and procedures to include all the requirements not part of the FCFPD?s current policies. 2. Make available the updated policies and procedures to responsible management and employees. 3. Management should monitor compliance and performance with the policies and procedures. View of Responsible Officials: Management agrees with the finding and has provided the accompanying corrective action plan.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Criteria or specific requirement: Per procurement standards, nonfederal entities other than States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. Per 2 CFR Section 200.319, procurement expenditures require documentation over the bidding process. Condition: During our testing, we identified transactions which the Organization contracted with a vendor for services that exceeded the $3,000 threshold (the Organizations? requirement per their procurement policy) and did not retain documentation for the bidding process for these services. Questioned costs: N/A Context: During our testing, we identified transactions which the Organization contracted with a vendor for services that exceeded the $3,000 threshold (the Organizations? requirement per their procurement policy) and did not retain documentation for the bidding process for these services. Cause: Client did not have a consistent process for ensuring the procurement processes were followed. Effect: Noncompliance could result in the Organization not obtaining the best pricing and spending the federal funds appropriately. Recommendation: We recommend that the Organization implement processes and procedures to ensure that all disbursements charged to the federal follow the proper procurement standards and to maintain support for the procurement methods used. Management Response: The Organization is reviewing and modifying the Purchase Requisition and Purchase Order Policy to reflect current practices more accurately, update federal regulations and associated purchase thresholds. In addition, the Organization is improving internal procedures to manage requisition submittals which reach thresholds that would dictate multiple bid submittals as well as ensure an annual training of the Organization?s management and purchasers on policy parameters.
Criteria: Per procurement standards, nonfederal entities other than States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. Per 2 CFR Section 200.319, procurement expenditures require documentation over the bidding process. Condition: During our testing of contracts above $25,000 to ensure that vendors are properly vetted to not be on the SAM.gov debarred vendors listing we noted no support showing that vendors were reviewed against the debarred vendors listing prior to entering into a contract. Questioned costs: N/A Context: During our testing of contracts above $25,000 to ensure that vendors are properly vetted to not be on the SAM.gov debarred vendors listing we noted no support showing that vendors were reviewed against the debarred vendors listing prior to entering into a contract. Cause: General error in lack of vendor verification due to lack of an oversight process in place. Effect: Debarred vendors could be used without proper verification. Recommendation: We recommend that the Organization implement processes and procedures to ensure that all vendors are reviewed against the debarred vendors listing prior to entering into the contract. Management Response: The Organization currently utilizes a third-party vendor, Compliatric, to screen vendors in accordance with SAM.gov requirements on a routine basis. However, a procedure does not currently exist to ensure 100% of new vendors are entered into this separate system. A procedure is being developed to ensure that all new vendors are entered into Compliatric and screening is completed prior to entering into a contract.
2022-002: Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Special Education Cluster (IDEA); Federal Assistance Listing Number 84.027, Special Education ? Grants to States; Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Criteria: 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but 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: Both of the samples we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. Cause: The School District only renewed the contracts and did not provide for an opportunity for competitive bidding procedures. Effect or Potential Effect: The School District could be paying more than a reasonable amount for the services provided. Recommendation: The School District should follow state and federal procurement guidelines and select contractors on a competitive basis. The School District went through proper bidding procedures for 2022-23 fiscal year for procurement of services. Management?s Response: See corrective action plan.
2022-002: Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Special Education Cluster (IDEA); Federal Assistance Listing Number 84.027, Special Education ? Grants to States; Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Criteria: 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but 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: Both of the samples we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. Cause: The School District only renewed the contracts and did not provide for an opportunity for competitive bidding procedures. Effect or Potential Effect: The School District could be paying more than a reasonable amount for the services provided. Recommendation: The School District should follow state and federal procurement guidelines and select contractors on a competitive basis. The School District went through proper bidding procedures for 2022-23 fiscal year for procurement of services. Management?s Response: See corrective action plan.
2022-002: Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Special Education Cluster (IDEA); Federal Assistance Listing Number 84.027, Special Education ? Grants to States; Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Criteria: 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but 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: Both of the samples we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. Cause: The School District only renewed the contracts and did not provide for an opportunity for competitive bidding procedures. Effect or Potential Effect: The School District could be paying more than a reasonable amount for the services provided. Recommendation: The School District should follow state and federal procurement guidelines and select contractors on a competitive basis. The School District went through proper bidding procedures for 2022-23 fiscal year for procurement of services. Management?s Response: See corrective action plan.
2022-002: Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Special Education Cluster (IDEA); Federal Assistance Listing Number 84.027, Special Education ? Grants to States; Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Criteria: 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but 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: Both of the samples we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. Cause: The School District only renewed the contracts and did not provide for an opportunity for competitive bidding procedures. Effect or Potential Effect: The School District could be paying more than a reasonable amount for the services provided. Recommendation: The School District should follow state and federal procurement guidelines and select contractors on a competitive basis. The School District went through proper bidding procedures for 2022-23 fiscal year for procurement of services. Management?s Response: See corrective action plan.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
2022-001 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 ? 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 do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. 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 reviews 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.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.