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.
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.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policy in effect for the year under audit, it was noted that policy did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. In addition, the District did not maintain documentation of the selection of vendors in compliance with Uniform Guidance for the five (5) small purchase transaction selected for testing, as part of a statistically valid sample. Questioned costs: N/A Context: The District's purchasing policy was adopted several years ago and the formal policy has not be updated for the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. For the 5 vendors selected for testing in a non-statistically valid sample, the District was not able to provide documentation of their compliance with the required vendor selection criteria. Cause: The District did not review and update the procurement policy in effect to comply with Uniform Guidance and update threshold identified in the most current updates to the Uniform Guidance. Effect: The District's purchasing policy in effect during the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procumbent methods, micro purchase and small purchase transactions. In addition, the District may not apply proper procurement requirements to transactions. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policy in effect for the year under audit, it was noted that policy did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. In addition, the District did not maintain documentation of the selection of vendors in compliance with Uniform Guidance for the five (5) small purchase transaction selected for testing, as part of a statistically valid sample. Questioned costs: N/A Context: The District's purchasing policy was adopted several years ago and the formal policy has not be updated for the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. For the 5 vendors selected for testing in a non-statistically valid sample, the District was not able to provide documentation of their compliance with the required vendor selection criteria. Cause: The District did not review and update the procurement policy in effect to comply with Uniform Guidance and update threshold identified in the most current updates to the Uniform Guidance. Effect: The District's purchasing policy in effect during the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procumbent methods, micro purchase and small purchase transactions. In addition, the District may not apply proper procurement requirements to transactions. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policy in effect for the year under audit, it was noted that policy did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. In addition, the District did not maintain documentation of the selection of vendors in compliance with Uniform Guidance for the five (5) small purchase transaction selected for testing, as part of a statistically valid sample. Questioned costs: N/A Context: The District's purchasing policy was adopted several years ago and the formal policy has not be updated for the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. For the 5 vendors selected for testing in a non-statistically valid sample, the District was not able to provide documentation of their compliance with the required vendor selection criteria. Cause: The District did not review and update the procurement policy in effect to comply with Uniform Guidance and update threshold identified in the most current updates to the Uniform Guidance. Effect: The District's purchasing policy in effect during the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procumbent methods, micro purchase and small purchase transactions. In addition, the District may not apply proper procurement requirements to transactions. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria ? Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition ? In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect ? A lack of documented policies increase 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 ? Overall procurement policy. Repeat Finding from Prior Years ? No Recommendation ? We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials ? There is no disagreement with the audit finding.