Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
U.S. Department of Housing and Urban Development Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina Program Name: Emergency Solutions Grant Federal Assistance Listing Number: 14.231 U.S. Department of Treasury Pass-through Entity: Mecklenburg County, North Carolina Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency and Nonmaterial Noncompliance – Procurement Finding 2024-003 Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management. Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services. Questioned Costs: None noted. Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor. Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested. Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding. Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.
U.S. Department of Housing and Urban Development Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina Program Name: Emergency Solutions Grant Federal Assistance Listing Number: 14.231 U.S. Department of Treasury Pass-through Entity: Mecklenburg County, North Carolina Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency and Nonmaterial Noncompliance – Procurement Finding 2024-003 Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management. Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services. Questioned Costs: None noted. Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor. Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested. Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding. Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.
U.S. Department of Housing and Urban Development Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina Program Name: Emergency Solutions Grant Federal Assistance Listing Number: 14.231 U.S. Department of Treasury Pass-through Entity: Mecklenburg County, North Carolina Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency and Nonmaterial Noncompliance – Procurement Finding 2024-003 Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management. Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services. Questioned Costs: None noted. Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor. Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested. Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding. Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.
U.S. Department of Housing and Urban Development Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina Program Name: Emergency Solutions Grant Federal Assistance Listing Number: 14.231 U.S. Department of Treasury Pass-through Entity: Mecklenburg County, North Carolina Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency and Nonmaterial Noncompliance – Procurement Finding 2024-003 Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management. Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services. Questioned Costs: None noted. Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor. Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested. Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding. Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.
U.S. Department of Housing and Urban Development Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina Program Name: Emergency Solutions Grant Federal Assistance Listing Number: 14.231 U.S. Department of Treasury Pass-through Entity: Mecklenburg County, North Carolina Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency and Nonmaterial Noncompliance – Procurement Finding 2024-003 Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management. Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services. Questioned Costs: None noted. Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor. Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested. Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding. Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.
Assistance Listing Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Award Number: N/A Federal Award Year: 2023/2024 Pass Through Entity: Chicago Cook Workforce Partnership Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by0 the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) - spacing 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization’s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: See corrective action plan attached to financial statements.
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: September 30, 2024 Responsible Persons: District Board, Umpqua Public Transit District
2024-002 – Material Weakness in Compliance and Internal Control over Procurement and Suspension and Debarment Identification of federal programs: U.S. Department of Housing and Urban Development: #14.251 Economic Development Initiative, Community Project Funding, and Misc. Grants, #B-22-CP-AK-0003 Criteria: Part 3 Compliance Supplement Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. § 200.318(a) Documented procurement procedures – The recipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. § 200.318(i) Procurement records - The recipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. § 200.320 Procurement methods – There are three types of procurement methods described: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319. § 200.214 Suspension and debarment – When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization procured certain goods or services from vendors but did not maintain evidence that they followed their procurement policy or the procurement requirements of the federal program. Cause: The Organization’s purchasing policy does not address all of the procurement requirements of Uniform Guidance. The Organization did not maintain sufficient documentation supporting purchases greater than the micro-purchase threshold or relating to suspension and debarment on certain covered transactions. In the period after year end and before the date of fieldwork, there was turnover in management in the Executive Director position so it is possible that competitive bidding was sought, but that the knowledge and communications have been lost during the transition. Effect or potential effect: The Organization is not in compliance with the procurement requirements of the Uniform Guidance. Questioned Costs: None Context: During the course of the audit of the major program, auditors requested copies of the required support for purchases from three vendors. Support was provided for one of the purchases but could not be located for two of the purchases. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that the Organization reviews and revises their procurement policies and procedures to ensure that they align with the requirements of Uniform Guidance. We also recommend that as part of the Organization’s internal control structure over compliance with procurement requirements, to establish monitoring procedures or checklists to ensure that support is obtained from a sufficient number of qualified sources depending on the purchasing threshold and method required to be used, and that evidence is retained to show that vendors were not suspended or debarred before entering into a transaction with them. Views of Responsible Officials: See Corrective Action Plan
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Procurement, Suspension and Debarment Criteria Procurement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow specific procurement standards set out in 2 CFR sections 200.317 through 200.327, which includes documenting the procurement methods used for vendor selection. These procedures are designed to ensure fair competition, cost-effectiveness, and federal requirements. These procurement standards require, among other provisions, that a non-federal entity must: 1. Meet the general procurement standards in 2 CFR Section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to reliable contractors, and maintaining records to document the history of procurement. 2. Conduct all procurement transactions for the acquisition of property or services under a federal award in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. 3. Use documented procurement procedures, consistent with the standards of 2 CFR 200.317 to 320. 2 CFR 200.320 enumerates below the different procurement methods that a non-federal entity should use: a) The micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $50,000. b) Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. c) Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. 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) (1); 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)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” Suspension and Debarment Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition During our audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, “Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval”. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred was performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Cause MARTA did not follow its existing purchasing policy and procedures, and lack of procedures in maintaining appropriate records of vendor selection and compliance with procurement standards. Effect The absence of procurement documentation raises the risk of non-compliance with federal regulations, which could lead to potential disallowances or unnecessary sanctions. Questioned Costs None Recommendation MARTA should strengthen its internal controls over procurement by ensuring that all procurement activities, particularly significant expenditures, are properly documented. This includes retaining evidence that procurement methods required by the Uniform Guidance were followed, such as bids, contracts, or justifications for sole-source vendors. MARTA should also conduct training for staff involved in procurement to ensure awareness and adherence to the policies. Regular internal audits may be implemented to verify compliance with procurement procedures. Views of Responsible Officials and Planned Corrective Action MARTA is in the process of updating the Procurement Policy. MARTA will ensure that updated policies and procedures will be implemented to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Procurement, Suspension and Debarment Criteria Procurement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow specific procurement standards set out in 2 CFR sections 200.317 through 200.327, which includes documenting the procurement methods used for vendor selection. These procedures are designed to ensure fair competition, cost-effectiveness, and federal requirements. These procurement standards require, among other provisions, that a non-federal entity must: 1. Meet the general procurement standards in 2 CFR Section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to reliable contractors, and maintaining records to document the history of procurement. 2. Conduct all procurement transactions for the acquisition of property or services under a federal award in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. 3. Use documented procurement procedures, consistent with the standards of 2 CFR 200.317 to 320. 2 CFR 200.320 enumerates below the different procurement methods that a non-federal entity should use: a) The micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $50,000. b) Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. c) Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. 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) (1); 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)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” Suspension and Debarment Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition During our audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, “Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval”. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred was performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Cause MARTA did not follow its existing purchasing policy and procedures, and lack of procedures in maintaining appropriate records of vendor selection and compliance with procurement standards. Effect The absence of procurement documentation raises the risk of non-compliance with federal regulations, which could lead to potential disallowances or unnecessary sanctions. Questioned Costs None Recommendation MARTA should strengthen its internal controls over procurement by ensuring that all procurement activities, particularly significant expenditures, are properly documented. This includes retaining evidence that procurement methods required by the Uniform Guidance were followed, such as bids, contracts, or justifications for sole-source vendors. MARTA should also conduct training for staff involved in procurement to ensure awareness and adherence to the policies. Regular internal audits may be implemented to verify compliance with procurement procedures. Views of Responsible Officials and Planned Corrective Action MARTA is in the process of updating the Procurement Policy. MARTA will ensure that updated policies and procedures will be implemented to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Procurement, Suspension and Debarment Criteria Procurement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow specific procurement standards set out in 2 CFR sections 200.317 through 200.327, which includes documenting the procurement methods used for vendor selection. These procedures are designed to ensure fair competition, cost-effectiveness, and federal requirements. These procurement standards require, among other provisions, that a non-federal entity must: 1. Meet the general procurement standards in 2 CFR Section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to reliable contractors, and maintaining records to document the history of procurement. 2. Conduct all procurement transactions for the acquisition of property or services under a federal award in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. 3. Use documented procurement procedures, consistent with the standards of 2 CFR 200.317 to 320. 2 CFR 200.320 enumerates below the different procurement methods that a non-federal entity should use: a) The micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $50,000. b) Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. c) Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. 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) (1); 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)). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” Suspension and Debarment Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition During our audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, “Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval”. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred was performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Cause MARTA did not follow its existing purchasing policy and procedures, and lack of procedures in maintaining appropriate records of vendor selection and compliance with procurement standards. Effect The absence of procurement documentation raises the risk of non-compliance with federal regulations, which could lead to potential disallowances or unnecessary sanctions. Questioned Costs None Recommendation MARTA should strengthen its internal controls over procurement by ensuring that all procurement activities, particularly significant expenditures, are properly documented. This includes retaining evidence that procurement methods required by the Uniform Guidance were followed, such as bids, contracts, or justifications for sole-source vendors. MARTA should also conduct training for staff involved in procurement to ensure awareness and adherence to the policies. Regular internal audits may be implemented to verify compliance with procurement procedures. Views of Responsible Officials and Planned Corrective Action MARTA is in the process of updating the Procurement Policy. MARTA will ensure that updated policies and procedures will be implemented to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Federal Agency: United States Department of Health and Human Services Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers 93.129, 93.527 Federal Award Year: 2023-2024 Criteria or specific requirement – Procurement (2 CFR 200.318) and suspension and debarment (2 CFR 180) The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Organization was unable to provide evidence it was in compliance with its procurement policy or that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Organization did not have adequate controls and procedures in place relating to procurement and suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – We were unable to determine whether the Organization complied with these compliance requirements. Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – The Organization was unable to provide a detailed expenditure listing by vendor to verify compliance with its procurement policy and compliance with Uniform Guidance. The Organization was also unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Identification as a Repeat Finding– Yes Recommendation – The Organization should incorporate internal controls over compliance with the procurement and suspension and debarment compliance requirements, including reviewing its procurement policy for compliance with Uniform Guidance and monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit finding related to procurement and suspension and debarment compliance under Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program (Federal Assistance Listing Numbers 93.129, 93.527; Federal Award Year 2023-2024). We are committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 2 CFR 200.318 and 2 CFR 180 regulations. Corrective Actions Taken: 1. Established & Implemented Detailed Record-Keeping for Procurement Transactions: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor invoices and procurement transactions in real time and syncs with Sage Intacct, the new accounting software implemented in January 2024. - Detailed records of all federal grant expenditures are maintained in Bill.com and monthly reconciliations are conducted in the general ledger to ensure all procurement transactions are properly classified to their specific grant by their grant ID. 2. Established & Implemented Suspension & Debarment Verification Procedures: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor information including Sam.gov vendor eligibility documentation. - All vendors are verified using Sam.gov. and documentation is kept in the electronic vendor file in Bill.com. This process was implemented in March 2024 and is ongoing. 3. Monitoring - The Finance team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.
Federal Agency: United States Department of Health and Human Services Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers 93.129, 93.527 Federal Award Year: 2023-2024 Criteria or specific requirement – Procurement (2 CFR 200.318) and suspension and debarment (2 CFR 180) The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Organization was unable to provide evidence it was in compliance with its procurement policy or that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Organization did not have adequate controls and procedures in place relating to procurement and suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – We were unable to determine whether the Organization complied with these compliance requirements. Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – The Organization was unable to provide a detailed expenditure listing by vendor to verify compliance with its procurement policy and compliance with Uniform Guidance. The Organization was also unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Identification as a Repeat Finding– Yes Recommendation – The Organization should incorporate internal controls over compliance with the procurement and suspension and debarment compliance requirements, including reviewing its procurement policy for compliance with Uniform Guidance and monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit finding related to procurement and suspension and debarment compliance under Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program (Federal Assistance Listing Numbers 93.129, 93.527; Federal Award Year 2023-2024). We are committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 2 CFR 200.318 and 2 CFR 180 regulations. Corrective Actions Taken: 1. Established & Implemented Detailed Record-Keeping for Procurement Transactions: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor invoices and procurement transactions in real time and syncs with Sage Intacct, the new accounting software implemented in January 2024. - Detailed records of all federal grant expenditures are maintained in Bill.com and monthly reconciliations are conducted in the general ledger to ensure all procurement transactions are properly classified to their specific grant by their grant ID. 2. Established & Implemented Suspension & Debarment Verification Procedures: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor information including Sam.gov vendor eligibility documentation. - All vendors are verified using Sam.gov. and documentation is kept in the electronic vendor file in Bill.com. This process was implemented in March 2024 and is ongoing. 3. Monitoring - The Finance team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.
Federal Agency: United States Department of Health and Human Services Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers 93.129, 93.527 Federal Award Year: 2023-2024 Criteria or specific requirement – Procurement (2 CFR 200.318) and suspension and debarment (2 CFR 180) The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Organization was unable to provide evidence it was in compliance with its procurement policy or that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Organization did not have adequate controls and procedures in place relating to procurement and suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – We were unable to determine whether the Organization complied with these compliance requirements. Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – The Organization was unable to provide a detailed expenditure listing by vendor to verify compliance with its procurement policy and compliance with Uniform Guidance. The Organization was also unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Identification as a Repeat Finding– Yes Recommendation – The Organization should incorporate internal controls over compliance with the procurement and suspension and debarment compliance requirements, including reviewing its procurement policy for compliance with Uniform Guidance and monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit finding related to procurement and suspension and debarment compliance under Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program (Federal Assistance Listing Numbers 93.129, 93.527; Federal Award Year 2023-2024). We are committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 2 CFR 200.318 and 2 CFR 180 regulations. Corrective Actions Taken: 1. Established & Implemented Detailed Record-Keeping for Procurement Transactions: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor invoices and procurement transactions in real time and syncs with Sage Intacct, the new accounting software implemented in January 2024. - Detailed records of all federal grant expenditures are maintained in Bill.com and monthly reconciliations are conducted in the general ledger to ensure all procurement transactions are properly classified to their specific grant by their grant ID. 2. Established & Implemented Suspension & Debarment Verification Procedures: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor information including Sam.gov vendor eligibility documentation. - All vendors are verified using Sam.gov. and documentation is kept in the electronic vendor file in Bill.com. This process was implemented in March 2024 and is ongoing. 3. Monitoring - The Finance team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: As a result of our procurement testing, we identified one (1) instance out of a population of one (1) where the County did not document the history of the procurement, including the rationale for method of procurement, selection of contract type, basis for contractor selection, and basis for the contract price. Cause: The County’s procurement policy and procedures do not comply with the uniform guidance requirements to obtain document the history of each procurement transaction. Effect: The County did not comply with the procurement, suspension and debarment requirements. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over procurement. We selected 100% of the procurements in the year under audit. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that the history of each procurement transaction. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
2024 – 002 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization did not have a written procurement policy in accordance with Uniform Guidance for a portion of the year. In addition, during our testing, we noted the Organization did not apply the proper procurement procedures for two vendors as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance. Questioned Costs: Unknown Context: Two out of the two procurement selections did not have procurement procedures followed. Cause: Vendors were procured prior to the implementation of a formal procurement policy; therefore, proper documentation was not retained as of the procurement date. Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards. Repeat Finding: This is a repeat finding. Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Views of Responsible Officials and Planned Corrective Actions: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements.
Condition: The Organization did not have documentation related to the suspension and debarment testing performed on vendors. Criteria: According to 2 CFR Section 200.318 and 2 CFR Section 200.326 of the Uniform Guidance, non-federal entities other than states must follow procurement standards when operating federal programs and the procurement procedures required depend on the amount of the transaction. Cause: The Organization was in the process of implementing the draft procurement policy as of June 30, 2024. The policy is properly designed and follows the Uniform Guidance. However, the policy was not implemented during the period under audit. Effect: There was an increased risk that the Organization was contracting and awarding contracts to suspended or debarred vendors.. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization implement a process to perform suspension and debarment testing as required by their procurement policy, and that as part of this process they maintain adequate supporting documentation and records to document suspension and debarment and the procedures performed to comply with the applicable CFR sections. This could include the use of standard forms and templates for suspension and debarment testing. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will develop an updated procurement policy that includes maintaining adequate supporting documentation and records regarding suspension and debarment procedures performed.
Condition: The Organization did not have documentation related to the suspension and debarment testing performed on vendors. Criteria: According to 2 CFR Section 200.318 and 2 CFR Section 200.326 of the Uniform Guidance, non-federal entities other than states must follow procurement standards when operating federal programs and the procurement procedures required depend on the amount of the transaction. Cause: The Organization was in the process of implementing the draft procurement policy as of June 30, 2024. The policy is properly designed and follows the Uniform Guidance. However, the policy was not implemented during the period under audit. Effect: There was an increased risk that the Organization was contracting and awarding contracts to suspended or debarred vendors.. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization implement a process to perform suspension and debarment testing as required by their procurement policy, and that as part of this process they maintain adequate supporting documentation and records to document suspension and debarment and the procedures performed to comply with the applicable CFR sections. This could include the use of standard forms and templates for suspension and debarment testing. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will develop an updated procurement policy that includes maintaining adequate supporting documentation and records regarding suspension and debarment procedures performed.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318 through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214 prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not comply with the procurement standards outlined in 2 CFR §200.318-§200.327, which require competitive procurement processes and verification that contractors are not suspended or debarred. Specifically, the county did not verify the eligibility of program recipients/participants/contractors through the System for Award Management (SAM) or equivalent documentation in order to verify that they were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws. Additionally, entities must ensure that all procurements provide full and open competition and take steps to utilize small and minority businesses, women's business enterprises, and labor surplus area firms when possible. Condition: The District's procurement policies do not comply with the federal procurement standards outlined in 2 CFR 200.318 through 200.327. Specifically, the policies lack adequate procedures to ensure full and open competition, and they do not include provisions addressing the use of small, minority-owned, and women-owned business enterprises as required by federal regulations. Cause: The District has not updated its procurement policies to reflect current federal requirements, which were revised under the Uniform Guidance. The lack of training and resources contributed to the oversight. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Child Nutrition Cluster. It also incresaes the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: Unknown. Recommendation: In order to correct the procurement process for Child Nutrition the client should revise the District's procurement policies to fully comply with 2 CFR 200.318 through 200.327, provide training for staff involved in procurement to ensure they understand and implement the updtaed policies, conduct periodic reviews of procurement activities to verify compliance with the revised policies, document efforts to engage small, minority-owned, and women-owned business enterprises in procurement activiites. Prior Year Finding: None. Auditee Response: See attached response.
2024-003 Significant Deficiency over Procurement Information on the Federal Program: Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, U.S. Department of the Treasury. Criteria: All entities under the program, must follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. Condition: We noted the County did not originally follow the procurement standards for their procurement of radio read water meters and installations. The County solicited price quotes for this contract. However, based on the amount of the contract, the County should have solicited a formal bid. Context/Cause: The County did not properly solicit for a formal bid for the radio read water meters and installation contract. The County was notified that the price quotes obtained would not be in compliance with the procurement standards and therefore solicited for a formal bid the contract. Effects: The County was not in compliance with the Federal and State procurement requirements. Recommendation: We recommend that the County implement a process to formally document all procurement actions and ensure the properly procurement based on the monetary amount of the contract. Auditee’s Response: We concur with the finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2024-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, and Suspension and Debarment Requirements Criteria – 2 CFR § 180 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the coronavirus state and local fiscal recovery funds federal program. Condition – During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Questioned Costs – None. Context – For nine of nine vendors exceeding the micro-purchase threshold, the District did not document its compliance with procurement policies and Uniform Guidance requirements related to methods of procurement, and documentation of compliance with suspension and debarment requirements was not maintained for four of four vendors tested to ensure compliance with this requirement in the current year. This was not a statistically valid sample. Repeat Finding – This is a current and prior year finding. Cause – This was an oversight by district personnel. Effect – Noncompliance with procurement, and suspension and debarment requirements could result in the District expending federal funds inappropriately or utilizing vendors that are not eligible to be parties to such transactions, which could be viewed as a violation of the award agreement. Recommendation – We recommend that the District review its internal control procedures relating to procurement, and suspension and debarment for the coronavirus state and local fiscal recovery funds federal program. Internal controls over compliance for this area should include documentation of procurement policies and Uniform Guidance requirements related to methods of procurement verification. These controls should also include steps to ensure any vendor with which the District contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.
FINDING 2023-003 – PROCUREMENT AND SUSPENSION AND DEBARMENT (Repeat Finding of 2022-003) Significant Deficiency FFINDING 2024-003 – PROCUREMENT AND SUSPENSION AND DEBARMENT Significant Deficiency Federal Programs: Charter Schools – Assistance Listing Number 84.282 Repeat Finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-003. Criteria 2 CFR 200.318(i) establishes the need to maintain records sufficient to detail the history of procurement. 2 CFR 180.300 establishes the responsibilities of participants entering into covered transactions. Condition The Organization lacked sufficient documentation to support the rationale of procurement methods, selection of contract types, contractor selection or rejection, and basis for the contract price. We also noted suspension and debarments requirements were not given consideration prior to entering into these transactions. However, we noted there were adequate invoices to support the purchases. Cause and Effect As described in 2024-001, the Organization has not established a formal process related to federal awards to identify all key compliance requirements and changes in compliance requirements, evaluate risks of noncompliance with these requirements, and respond to such risks of noncompliance through establishing or changing processes and internal controls. Additionally, certain individuals, within a department, responsible for the use of federal funds lacked knowledge of the compliance requirements pertaining to the use of the funds. As a result, they did not comply with requirements for proper procurement or in relation to suspension and debarment. Recommendation We recommend the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Views of Responsible Officials and Planned Corrective Actions The Organization’s Corrective Action Plan is included on pages 42 through 44.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR part 200 of the Uniform Guidance. 2 CFR §§ 200.318 through 200.326 of the Uniform Guidance outline procurement requirements for all non-payroll direct expenditures. Entities expending federal monies are required to follow Uniform Guidance procurement standards. 2 CFR 200.318(i) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District considered the contracts with Educational Service Centers to be noncompetitive procurements; however, the School District was unable to provide documentation that they met the criteria established in 2 CFR 200.320(c) to be considered as such. Due to a lack of internal controls over federal procurement documentation, the District did not properly maintain required supporting documentation. Failure to follow federal procurement standards, may result in the misuse of public funds, loss of "low risk auditee" status, increased audit expenses, loss of future federal awards, findings for recovery or other audit adjustments. The School District should review and follow the established Procurement policy to ensure proper procurement procedures are followed and sufficiently documented.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR part 200 of the Uniform Guidance. 2 CFR §§ 200.318 through 200.326 of the Uniform Guidance outline procurement requirements for all non-payroll direct expenditures. Entities expending federal monies are required to follow Uniform Guidance procurement standards. 2 CFR 200.318(i) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District considered the contracts with Educational Service Centers to be noncompetitive procurements; however, the School District was unable to provide documentation that they met the criteria established in 2 CFR 200.320(c) to be considered as such. Due to a lack of internal controls over federal procurement documentation, the District did not properly maintain required supporting documentation. Failure to follow federal procurement standards, may result in the misuse of public funds, loss of "low risk auditee" status, increased audit expenses, loss of future federal awards, findings for recovery or other audit adjustments. The School District should review and follow the established Procurement policy to ensure proper procurement procedures are followed and sufficiently documented.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR part 200 of the Uniform Guidance. 2 CFR §§ 200.318 through 200.326 of the Uniform Guidance outline procurement requirements for all non-payroll direct expenditures. Entities expending federal monies are required to follow Uniform Guidance procurement standards. 2 CFR 200.318(i) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The School District considered the contracts with Educational Service Centers to be noncompetitive procurements; however, the School District was unable to provide documentation that they met the criteria established in 2 CFR 200.320(c) to be considered as such. Due to a lack of internal controls over federal procurement documentation, the District did not properly maintain required supporting documentation. Failure to follow federal procurement standards, may result in the misuse of public funds, loss of "low risk auditee" status, increased audit expenses, loss of future federal awards, findings for recovery or other audit adjustments. The School District should review and follow the established Procurement policy to ensure proper procurement procedures are followed and sufficiently documented.
Under 2 CFR 200.318-326, non-federal entities must adhere to procurement standards for purchases made with federal funds. Key requirements include: - Full and Open Competition: Procurement transactions must be conducted to ensure open competition and prevent practices that may unduly restrict competition (2 CFR 200.319(a)). - Documentation of Procurement History: Entities must maintain records that detail the procurement history, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318(i)). - Use of Non-Competitive Procurement: Non-competitive procurement is only allowed under limited circumstances, such as when the item is available from a single source, there is a public emergency, or after solicitation of multiple sources, competition is deemed inadequate (2 CFR 200.320(c)).The Organization incurred expenditures of approximately $620,000 for the renovation of a community center using federal funds under the SLFRF program. The Organization received two bids for the renovation project. However, full documentation of the process was not maintained. Cause: The Organization did not establish or follow sufficient internal controls to ensure compliance with federal procurement requirements, including maintaining the required documentation for procurement activities. Possible effect: The lack of procurement documentation creates a significant risk that noncompliant practices occurred, such as non-competitive procurement or payments exceeding fair market value.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.