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.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred. Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample. Cause: District policy for procurement was not enforced. Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds. Questioned Costs: None noted. Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible. Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred. Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample. Cause: District policy for procurement was not enforced. Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds. Questioned Costs: None noted. Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible. Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Finding 2024-003: Significant Deficiency - Internal Control and Compliance Over Procurement Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: Guidance provided in 2 CFR part 200.318 requires non-federal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. A system of internal controls should be in place to ensure procurement policies are being adhered to. There are also requirements to verify the vendors are not suspended or debarred. Condition/Context: There was no documented approval of one of the two procurements tested. The food service director handled the procurement of kitchen equipment and no documentation of review by a different appropriate individual was noted. Additionally, it is unclear whether suspension or debarment of the vendor was considered. The sample was not a statistically valid sample. Cause: District policy for procurement was not enforced. Effect: This could potentially lead to higher costs for the food service program or selection of vendors who are not eligible to be paid with federal funds. Questioned Costs: None noted. Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for federal programs and the District's policies and implement process changes as soon as possible. Views of Responsible Officials: Management agrees with finding 2024-003 and will make efforts to implement recommended procedures.
Questioned costs: Impossible to quantify, given the nature of the finding. Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Criteria: Per 2 CFR Sec. 200.318(a), “[t]he 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. 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.” Effect: The Organization was not in compliance with the requirements of the Uniform Guidance. Lack of formal documentation of the Organization’s procurement procedures increases the likelihood that staff is unaware of the procedures and updates to them, which increases the chances that staff is noncompliant with the applicable requirements. Cause: The Organization inadvertently did not document its procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Recommendation (2024-001-a): We recommend that management draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Management’s Response: Management concurs with this finding and agrees with the auditor’s recommendations.
Questioned costs: Impossible to quantify, given the nature of the finding. Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Criteria: Per 2 CFR Sec. 200.318(a), “[t]he 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. 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.” Effect: The Organization was not in compliance with the requirements of the Uniform Guidance. Lack of formal documentation of the Organization’s procurement procedures increases the likelihood that staff is unaware of the procedures and updates to them, which increases the chances that staff is noncompliant with the applicable requirements. Cause: The Organization inadvertently did not document its procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Recommendation (2024-001-a): We recommend that management draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Management’s Response: Management concurs with this finding and agrees with the auditor’s recommendations.
Questioned costs: Impossible to quantify, given the nature of the finding. Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Criteria: Per 2 CFR Sec. 200.318(a), “[t]he 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. 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.” Effect: The Organization was not in compliance with the requirements of the Uniform Guidance. Lack of formal documentation of the Organization’s procurement procedures increases the likelihood that staff is unaware of the procedures and updates to them, which increases the chances that staff is noncompliant with the applicable requirements. Cause: The Organization inadvertently did not document its procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Recommendation (2024-001-a): We recommend that management draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Management’s Response: Management concurs with this finding and agrees with the auditor’s recommendations.
Questioned costs: Impossible to quantify, given the nature of the finding. Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Criteria: Per 2 CFR Sec. 200.318(a), “[t]he 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. 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.” Effect: The Organization was not in compliance with the requirements of the Uniform Guidance. Lack of formal documentation of the Organization’s procurement procedures increases the likelihood that staff is unaware of the procedures and updates to them, which increases the chances that staff is noncompliant with the applicable requirements. Cause: The Organization inadvertently did not document its procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Recommendation (2024-001-a): We recommend that management draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Management’s Response: Management concurs with this finding and agrees with the auditor’s recommendations.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Procurement, Suspension and Debarment PROCUREMENT COMPLIANCE RIDE did not ensure that three out of five School Food Authorities (SFA) submitted their written code of standards of conduct as required by federal regulations before approving their procurement. Background: RIDE reviews and approves the SFA procurement procedures regarding procuring a Food Service Management Company (FSMC). To ensure compliance, RIDE makes available a template for policy and procedures, the code of standards of conduct, and the whole procurement process as it pertains to the SFA procuring a Food Service Management Company (FSMC). Criteria: Federal regulation 7 CFR §210.21(c) requires that SFA, where applicable, must submit a written code of standards of conduct meeting the minimum standards of 2 CFR §200.318 to RIDE during their procurement process. Condition: Due to the materiality of the expenditures relating to FSMC procurements, we selected 2 of the 5 FSMC procurements in conjunction with our procurement testing of all vendors. Our testing noted that RIDE approved one SFA’s procurement of a FSMC, without having the SFA’s required written code of standards of conduct. We followed up with RIDE to determine if this was an isolated instance and found that the code of standards of conduct was missing in 3 out of 5 procurements. Cause: RIDE’s policies, procedures and controls were not adequate to ensure that the Department received the SFA’s written code of standards of conduct before approving the SFA’s procurement of a FSMC. Effect: RIDE is not in compliance with 7 CFR §210.21(c) which requires the SFA to submit a written code of standards of conduct to RIDE with the minimum standards stated in 2 CFR §200.318. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-032 Establish policies and procedures in conjunction with formalizing internal control to ensure compliance of 7 CFR §210.21(c) by requiring SFAs to submit a written code of standards of conduct at the beginning of the procurement process.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Procurement, Suspension and Debarment PROCUREMENT COMPLIANCE RIDE did not ensure that three out of five School Food Authorities (SFA) submitted their written code of standards of conduct as required by federal regulations before approving their procurement. Background: RIDE reviews and approves the SFA procurement procedures regarding procuring a Food Service Management Company (FSMC). To ensure compliance, RIDE makes available a template for policy and procedures, the code of standards of conduct, and the whole procurement process as it pertains to the SFA procuring a Food Service Management Company (FSMC). Criteria: Federal regulation 7 CFR §210.21(c) requires that SFA, where applicable, must submit a written code of standards of conduct meeting the minimum standards of 2 CFR §200.318 to RIDE during their procurement process. Condition: Due to the materiality of the expenditures relating to FSMC procurements, we selected 2 of the 5 FSMC procurements in conjunction with our procurement testing of all vendors. Our testing noted that RIDE approved one SFA’s procurement of a FSMC, without having the SFA’s required written code of standards of conduct. We followed up with RIDE to determine if this was an isolated instance and found that the code of standards of conduct was missing in 3 out of 5 procurements. Cause: RIDE’s policies, procedures and controls were not adequate to ensure that the Department received the SFA’s written code of standards of conduct before approving the SFA’s procurement of a FSMC. Effect: RIDE is not in compliance with 7 CFR §210.21(c) which requires the SFA to submit a written code of standards of conduct to RIDE with the minimum standards stated in 2 CFR §200.318. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-032 Establish policies and procedures in conjunction with formalizing internal control to ensure compliance of 7 CFR §210.21(c) by requiring SFAs to submit a written code of standards of conduct at the beginning of the procurement process.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Procurement, Suspension and Debarment PROCUREMENT COMPLIANCE RIDE did not ensure that three out of five School Food Authorities (SFA) submitted their written code of standards of conduct as required by federal regulations before approving their procurement. Background: RIDE reviews and approves the SFA procurement procedures regarding procuring a Food Service Management Company (FSMC). To ensure compliance, RIDE makes available a template for policy and procedures, the code of standards of conduct, and the whole procurement process as it pertains to the SFA procuring a Food Service Management Company (FSMC). Criteria: Federal regulation 7 CFR §210.21(c) requires that SFA, where applicable, must submit a written code of standards of conduct meeting the minimum standards of 2 CFR §200.318 to RIDE during their procurement process. Condition: Due to the materiality of the expenditures relating to FSMC procurements, we selected 2 of the 5 FSMC procurements in conjunction with our procurement testing of all vendors. Our testing noted that RIDE approved one SFA’s procurement of a FSMC, without having the SFA’s required written code of standards of conduct. We followed up with RIDE to determine if this was an isolated instance and found that the code of standards of conduct was missing in 3 out of 5 procurements. Cause: RIDE’s policies, procedures and controls were not adequate to ensure that the Department received the SFA’s written code of standards of conduct before approving the SFA’s procurement of a FSMC. Effect: RIDE is not in compliance with 7 CFR §210.21(c) which requires the SFA to submit a written code of standards of conduct to RIDE with the minimum standards stated in 2 CFR §200.318. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-032 Establish policies and procedures in conjunction with formalizing internal control to ensure compliance of 7 CFR §210.21(c) by requiring SFAs to submit a written code of standards of conduct at the beginning of the procurement process.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Procurement, Suspension and Debarment PROCUREMENT COMPLIANCE RIDE did not ensure that three out of five School Food Authorities (SFA) submitted their written code of standards of conduct as required by federal regulations before approving their procurement. Background: RIDE reviews and approves the SFA procurement procedures regarding procuring a Food Service Management Company (FSMC). To ensure compliance, RIDE makes available a template for policy and procedures, the code of standards of conduct, and the whole procurement process as it pertains to the SFA procuring a Food Service Management Company (FSMC). Criteria: Federal regulation 7 CFR §210.21(c) requires that SFA, where applicable, must submit a written code of standards of conduct meeting the minimum standards of 2 CFR §200.318 to RIDE during their procurement process. Condition: Due to the materiality of the expenditures relating to FSMC procurements, we selected 2 of the 5 FSMC procurements in conjunction with our procurement testing of all vendors. Our testing noted that RIDE approved one SFA’s procurement of a FSMC, without having the SFA’s required written code of standards of conduct. We followed up with RIDE to determine if this was an isolated instance and found that the code of standards of conduct was missing in 3 out of 5 procurements. Cause: RIDE’s policies, procedures and controls were not adequate to ensure that the Department received the SFA’s written code of standards of conduct before approving the SFA’s procurement of a FSMC. Effect: RIDE is not in compliance with 7 CFR §210.21(c) which requires the SFA to submit a written code of standards of conduct to RIDE with the minimum standards stated in 2 CFR §200.318. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-032 Establish policies and procedures in conjunction with formalizing internal control to ensure compliance of 7 CFR §210.21(c) by requiring SFAs to submit a written code of standards of conduct at the beginning of the procurement process.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Procurement, Suspension and Debarment PROCUREMENT COMPLIANCE RIDE did not ensure that three out of five School Food Authorities (SFA) submitted their written code of standards of conduct as required by federal regulations before approving their procurement. Background: RIDE reviews and approves the SFA procurement procedures regarding procuring a Food Service Management Company (FSMC). To ensure compliance, RIDE makes available a template for policy and procedures, the code of standards of conduct, and the whole procurement process as it pertains to the SFA procuring a Food Service Management Company (FSMC). Criteria: Federal regulation 7 CFR §210.21(c) requires that SFA, where applicable, must submit a written code of standards of conduct meeting the minimum standards of 2 CFR §200.318 to RIDE during their procurement process. Condition: Due to the materiality of the expenditures relating to FSMC procurements, we selected 2 of the 5 FSMC procurements in conjunction with our procurement testing of all vendors. Our testing noted that RIDE approved one SFA’s procurement of a FSMC, without having the SFA’s required written code of standards of conduct. We followed up with RIDE to determine if this was an isolated instance and found that the code of standards of conduct was missing in 3 out of 5 procurements. Cause: RIDE’s policies, procedures and controls were not adequate to ensure that the Department received the SFA’s written code of standards of conduct before approving the SFA’s procurement of a FSMC. Effect: RIDE is not in compliance with 7 CFR §210.21(c) which requires the SFA to submit a written code of standards of conduct to RIDE with the minimum standards stated in 2 CFR §200.318. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-032 Establish policies and procedures in conjunction with formalizing internal control to ensure compliance of 7 CFR §210.21(c) by requiring SFAs to submit a written code of standards of conduct at the beginning of the procurement process.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, 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 https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 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. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. 2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. 2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member. A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law. Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds. Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. 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 (including a cost or price analysis). The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above. Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding. The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. 2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. 2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member. A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law. Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds. Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. 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 (including a cost or price analysis). The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above. Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding. The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. 2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. 2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member. A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law. Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds. Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. 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 (including a cost or price analysis). The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above. Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding. The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR § 200.320(b) states in part that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. 2 CFR § 200.318(e) states to foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. 2 CFR §200.320(2)(a) states for small purchases the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Ohio Rev. Code § 167.081, states that a regional council may enter into a unit price contract for materials, labor, services, overhead, profit, and associated expenses for the repair, enlargement, improvement, or demolition of a building or structure if the contract is awarded pursuant to a competitive bidding procedure of a county, municipal corporation, or township or a special district, school district, or other political subdivision that is a council member. A political subdivision that is a member of a regional council may participate in a contract entered into under Ohio Rev. Code § 167.081. Purchases under a contract entered into under Ohio Rev. Code § 167.081 are exempt from any competitive selection or bidding requirements otherwise required by law. Furthermore, the District’s Procurement – Federal Grants/Funds Policy (#6325) details the District’s procedures for procurement with federal funds. Specifically, Maintenance of Procurement Records: The District shall maintain records sufficient to detail the history of all procurements. 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 (including a cost or price analysis). The District participated in The Ohio Purchasing Council’s unit price contract with Prodigy Building Solutions, LLC., for the School District's roofing, HVAC, and Lighting project, pursuant to Ohio Rev. Code § 167.081. The School District utilized ESSER grant funds for parts of these projects. The School District did not maintain documentation that Ohio Purchasing Council followed competitive bidding procedures of a council member pursuant to O.R.C. 167.081 when awarding the unit price contract to Prodigy Building Solutions respectively, failing to meet the documentation requirements of 2 CFR § 200.320(b) and 2 CFR § 200.318(e) noted above. Failure to comply with the applicable Uniform Guidance Requirements and the Ohio Revised Code could result in misuse of public funds, potential questioned costs, and/or potential loss of grant funding. The District should review its policy, Uniform Guidance requirements, and the Ohio Revised Code before entering into any contracts that require competitive bidding. In addition, the District should fully implement its procurement policy.
2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR § 200.318 through 200.327 which describe specific procedures non-Federal entities must follow when entering into procurement transactions using Federal funds. 2 CFR § 200.320(a)(2) indicates, in part, when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold, but does not exceed the simplified acquisition threshold, simplified acquisition procedures can be used. If simplified acquisition procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined by the recipient or subrecipient. 2 CFR § 200.318(i) indicates the non-Federal entity must maintain records sufficient to detail the history of procurement transaction. These records must 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. Due to a lack of controls over the procurement process, for one out of two vendors examined during testing of the Coronavirus State and Local Fiscal Recovery Funds grant, the District did not obtain quotes from other vendors. The procurement was below the simplified acquisition threshold and above the micro-purchase threshold; therefore, small purchase procedures require the District to obtain “price or rate quotations from an adequate number of qualified sources as determined appropriate by” the District. The District’s procurement policy does not specify the number and form of quotations required under small purchasing procedures. Failure to obtain quotations from a variety of vendors may result in the District not utilizing the most cost effective vendor as well as further noncompliance with Federal requirements. The District should adopt procedures to help ensure records are maintained to document the history of the procurement, including the rationale for the purchase method, selection of vendors, cost/price analysis (if applicable) and the reason for limiting competition (if applicable). The District should also amend its procurement policy to indicate the number and form of quotations required when using small purchase procedures.
Federal Agency: U.S. Department of Health and Human Services Federal Program: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects – ALN 93.048 Criteria Uniform Guidance 2 CFR 200, Section 200.318 requires the Organization to maintain and use its own documented procurement procedures which reflect applicable federal, state and local laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in 2 CFR 200, Sections 200.318 through 200.327. Condition and Context The Organization’s current documented procurement policy does not contain all the required elements identified within the Uniform Guidance. Questioned Costs None Cause The Organization was not aware of all the procurement requirements under the Uniform Guidance. Effect or Potential Effect The Organization may procure goods and services that do not comply with the requirements under the Uniform Guidance, including not following required specific procurement methods, conducting procurement transactions that do not provide full and open competition, and entering into transactions that have conflicts of interest, among others. Recommendation The Organization should adopt a formal procurement policy that complies with 2 CFR 200, Sections 200.318 through 200.327. Views of Responsible Officials and Planned Corrective Action Management will review the requirements under the Uniform Guidance relating to procurement and establish a formal policy and related procedures to comply with those requirements.
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Voyager Sopris Learning ($49,117) and Questeq ($70,549). This is a repeat procurement finding from (2023-004) from the previous fiscal year. CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, or 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. QUESTIONED COST: $119,666 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, and 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Voyager Sopris Learning ($49,117) and Questeq ($70,549). This is a repeat procurement finding from (2023-004) from the previous fiscal year. CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, or 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. QUESTIONED COST: $119,666 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, and 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Voyager Sopris Learning ($49,117) and Questeq ($70,549). This is a repeat procurement finding from (2023-004) from the previous fiscal year. CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, or 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. QUESTIONED COST: $119,666 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, and 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
Finding Number: 2024‐001 Procurement Finding Repeat Finding: No Questioned Costs: None Funding Agency: Department of Education AL Number: 84.351A Award Year: 10/1/2023 – 9/30/2024 Condition: The Organization does not have a procurement policy that follows the federal regulations. Criteria: The Organization should follow the Uniform Guidance requirement 2 CFR 200.318(a), which requires the Organization to maintain and use documented procedures for procurement transactions under Federal awards that are consistent with the Uniform Guidance procurement standards. Cause: The Organization’s existing procurement standards do not align with federal regulations. This is the first year the Organization has a federal program. Effect: The Organization was not in compliance with Uniform Guidance requirements, resulting in a significant deficiency in internal control over compliance. Recommendations: We recommend that the Organization update their procurement standards to align with what is required by the Uniform Guidance. View of Responsible Officials: Management agrees with the finding and has committed to implementing a corrective action plan.
2024-002: Procurement Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization’s procurement policies were not followed when selecting the major contractors for the expansion project. Specifically, there was no documentation maintained for federal compliance checks or the evaluation and ranking of candidates by the infrastructure committee. 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; this includes maintaining records that detail the history of procurement. Cause: The organization does not have effective controls in place to ensure the procurement policies and procedures are followed. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Coronavirus State and Local Fiscal Recovery Funds program. It also increases the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 contractors was selected for testing of Procurement. Repeat Finding from Prior Year: No. Recommendation: The organization should provide training for staff involved in procurement to ensure they understand and follow the documented policies, conduct periodic reviews of procurement activities to verify compliance with the policies, and maintain documentation of the procurement activities. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. We have taken steps to strengthen compliance and oversight. We are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve a designated Construction Manager to monitor compliance with standardized procedures and reporting throughout the project, that meeting minutes are properly recorded by the grantor’s requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. ACLAMO will provide mandatory training for all staff involved in the procurement process and will conduct a comprehensive review of its procurement policy to ensure alignment with Uniform Guidance.
U.S. Department of Health and Human Services Federal Financial Assistance Listing Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 1H79SM088927-01 Procurement and Suspension and Debarment Material Weakness in Internal Control over Compliance and Noncompliance Criteria The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.318 through 200.327. Condition The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. In addition, the Organization entered into a contract with a vendor for services without obtaining quotes from other vendors. Cause There is a lack of controls over the written procurement, suspension and debarment policy and over procurement, suspension and debarment as a whole. Effect Failure to maintain a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations may result in disallowed costs. Questioned Costs $37,000 was paid during fiscal year 2024 to a vendor without obtaining quotes. Context/Sampling EB reviewed the procurement, suspension and debarment policy. A nonstatistical sample of 3 vendors were selected for testing. Of these 3, 1 did not follow appropriate procurement, suspension and debarment procedures. Repeat Finding from Prior Year(s) Yes Recommendation We recommend that management implement a written procurement, suspension and debarment policy that meets Federal, State, local, and tribal laws and regulations. We recommend that management review this policy regularly to confirm that it meets the requirements. We also recommend that management review this policy prior to entering into any contracts with vendors. Views of Responsible Individuals Management agrees with the finding.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0504L3T002110 - FY24, PA0504L3T002211 - FY24, PA0911L3T002103 - FY24, PA0911L3T002204 - FY24, PA1067L3T002200 - FY24 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Controls over Procurement, Suspension and Debarment Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: We noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization’s conflict of interest policy, procurement, suspension and debarment requirements and the requirements of Uniform Guidance. Questioned Costs: Known: $74,275 Context: Lack of contracts, agreements and procurement procedures when acquiring vendors for federal grant expenditures. Through our testing of 40 vendors, we identified 4 which did not follow the proper procurement, suspension and debarment practices per federal requirements. Of these 4 vendors, we identified a total of $74,275 of known questioned costs within the program tested, and furthermore $190,515 of likely questioned costs based on the population. Cause: The Organization had procured vendors without following the required procurement, suspension and debarment procedures. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend that management review the procurement, suspension, and debarment requirements for federal programs as well as the organization's policies related to these areas. Management should ensure that such practices are being followed to comply with federal requirements. We also recommend that all current vendors in use are assessed and considered for compliance with procurement, suspension and debarment practices. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. See attached corrective action plan.