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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
United States Department of Treasury Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA) Significant deficiency over Procurement and Suspension and Debarment Repeat Finding: No Condition: During our audit we noted that procurement documentation was not available to support the selection of a sole source vendor. Also, we were unable to obtain documentation to support BCI entering into contractual agreements with vendors who were not debarred or suspended from doing business with the Federal government. Criteria: In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides guidance on internal controls over Federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. Per 2 CFR 200.320 General procurement stands: (a) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold .(2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Per 2 CFR 200.318 General procurement stands: (b) The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Per Uniform Guidance, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Cause: BCI did not apply the required procurement policy relative to sole source contracts in accordance with Uniform Guidance. Management also did not complete a review of vendors/contractors to verify they are not suspended, debarred, or otherwise excluded before contracting. Effect: The Organization does not have adequate documentation on whether they have entered into transactions with eligible entities and is in compliance with Federal guidelines. Questioned Costs: Unknown Recommendation: We recommend the Organization update and follow their controls to identify vendors that should go through the procurement process. We also recommend the Organization follow their process to verify that entities are not suspended, debarred, or otherwise excluded annually at time of award and to document these procedures. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the Corrective Action Plan. Auditor’s Conclusion: Finding remains as stated.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
FINDING 2023-001 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-034-PN01, 23611-034-PN01, 22611-034-ARP, 21619-034-PN01; 22619-034-PN01, 23619-034-PN01, 22619-034-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of 23 vendor claims were determined to require small purchase procedures. Of the vendor claims, totaling $113,815, 4 were selected for testing. For the 4 vendor claims tested, the School Corporation did not obtain an adequate number of price or rate quotations nor was its documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the School Corporation, it was determined that the School Corporation ensures all service contracts include a provision regarding suspension and debarment. The contracts are reviewed and signed by a knowledgeable member of the School Corporation. A population of eight covered transactions for goods or services that equaled or exceeded $25,000 paid from SPED funds during the audit period was identified. A sample of two transactions, totaling $178,915, was selected for testing. For both transactions, the School Corporation did not verify the vendors' suspension and debarment status prior to payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal control in the Federal Government' issued by the Comptroller General of the United States or the "Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) 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 §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Small purchases– (i) Small purchase procedures. 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. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to, and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-034-PN01, 23611-034-PN01, 22611-034-ARP, 21619-034-PN01; 22619-034-PN01, 23619-034-PN01, 22619-034-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of 23 vendor claims were determined to require small purchase procedures. Of the vendor claims, totaling $113,815, 4 were selected for testing. For the 4 vendor claims tested, the School Corporation did not obtain an adequate number of price or rate quotations nor was its documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the School Corporation, it was determined that the School Corporation ensures all service contracts include a provision regarding suspension and debarment. The contracts are reviewed and signed by a knowledgeable member of the School Corporation. A population of eight covered transactions for goods or services that equaled or exceeded $25,000 paid from SPED funds during the audit period was identified. A sample of two transactions, totaling $178,915, was selected for testing. For both transactions, the School Corporation did not verify the vendors' suspension and debarment status prior to payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal control in the Federal Government' issued by the Comptroller General of the United States or the "Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) 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 §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Small purchases– (i) Small purchase procedures. 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. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to, and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-034-PN01, 23611-034-PN01, 22611-034-ARP, 21619-034-PN01; 22619-034-PN01, 23619-034-PN01, 22619-034-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of 23 vendor claims were determined to require small purchase procedures. Of the vendor claims, totaling $113,815, 4 were selected for testing. For the 4 vendor claims tested, the School Corporation did not obtain an adequate number of price or rate quotations nor was its documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the School Corporation, it was determined that the School Corporation ensures all service contracts include a provision regarding suspension and debarment. The contracts are reviewed and signed by a knowledgeable member of the School Corporation. A population of eight covered transactions for goods or services that equaled or exceeded $25,000 paid from SPED funds during the audit period was identified. A sample of two transactions, totaling $178,915, was selected for testing. For both transactions, the School Corporation did not verify the vendors' suspension and debarment status prior to payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal control in the Federal Government' issued by the Comptroller General of the United States or the "Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) 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 §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Small purchases– (i) Small purchase procedures. 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. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to, and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-034-PN01, 23611-034-PN01, 22611-034-ARP, 21619-034-PN01; 22619-034-PN01, 23619-034-PN01, 22619-034-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of 23 vendor claims were determined to require small purchase procedures. Of the vendor claims, totaling $113,815, 4 were selected for testing. For the 4 vendor claims tested, the School Corporation did not obtain an adequate number of price or rate quotations nor was its documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the School Corporation, it was determined that the School Corporation ensures all service contracts include a provision regarding suspension and debarment. The contracts are reviewed and signed by a knowledgeable member of the School Corporation. A population of eight covered transactions for goods or services that equaled or exceeded $25,000 paid from SPED funds during the audit period was identified. A sample of two transactions, totaling $178,915, was selected for testing. For both transactions, the School Corporation did not verify the vendors' suspension and debarment status prior to payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal control in the Federal Government' issued by the Comptroller General of the United States or the "Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) 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 §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Small purchases– (i) Small purchase procedures. 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. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to, and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.
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. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.