2 CFR 200 § 200.318

Findings Citing § 200.318

General procurement standards.

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About this section
Section 200.318 requires recipients and subrecipients of federal awards to have documented procurement procedures that comply with applicable laws and ensure oversight of contractors. It also mandates written standards to prevent conflicts of interest among employees involved in contract management, prohibiting them from participating in contracts where they have a personal financial interest.
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FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Independant School District No. 152
Compliance Requirement: I
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, ...

2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.

FY End: 2024-06-30
Escondido Union School District
Compliance Requirement: I
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “sm...

Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.

FY End: 2024-06-30
Escondido Union School District
Compliance Requirement: I
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “sm...

Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.

FY End: 2024-06-30
Escondido Union School District
Compliance Requirement: I
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “sm...

Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.

FY End: 2024-06-30
Escondido Union School District
Compliance Requirement: I
Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “sm...

Finding 2024-001: Procurement (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Condition: During our testing of procurement, we sampled one contract that would qualify as “small purchases.” The district could not provide evidence that multiple quotes had been obtain prior to selecting one of the vendors. Expenditures for the vendor totaled $53,132. The District has a $50,000 threshold. Additionally, we sampled three contracts that exceed the simplified acquisition threshold and require competitive bidding or the noncompetitive proposals method of procurement. The District could not provide evidence of proper procurement procedure for either method in one of three instances for $751,360. Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases are awarded after a reasonable number of quotes have been obtained. Context: Deficiency was noted in two of four vendors tested. Questioned Cost: $804,492 in awarded contracts. Effect: This resulted in roughly $804,492 dollars awarded in contracts, without following proper procedures. Recommendation: We recommend that the District train and implement the required federal procurement procedures to ensure that the District is in compliance. Views of Responsible Officials: The Hollandia Dairy bid in question was originally for the 2020-2021 school year, and the audit inquiry was related to the 2023-2024 school year. Upon reviewing the bid, we realized that a new bid should have been issued for the 2023-2024 school year. This oversight was unintentional. However, we did conduct a bid for Hollandia Dairy this year (2024-2025), but unfortunately, no other bidders responded to our solicitation. To prevent similar issues from occurring in the future, we will implement a dedicated district system to track all formal bids, informal bids, and RFQs by contract year. This will be done through a combination of individual files and a shared Google document within the Nutrition Drive. This process will help us maintain proper documentation and ensure compliance with procurement requirements moving forward. The live Google document will include key information such as bid solicitation dates, contract dates, and renewal dates for all Nutrition Services bids, RFPs, RFQs, and micro-purchases. Additionally, the Nutrition Services Director will review all contracts at the beginning of each school year before issuing a purchase order to verify that we are in compliance with federal procurement procedures.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Co...

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Co...

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Co...

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Co...

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Co...

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

FY End: 2024-06-30
City of Norwalk, Connecticut
Compliance Requirement: I
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requ...

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

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