Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
2023 – 003 Procurement and Suspension and Debarment Federal Agency: U.S. Department Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified. Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: Unknown Context: 6 of 6 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation. Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. County policies have not been updated yet. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-003. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003 Procurement and Suspension and Debarment Federal Agency: U.S. Department Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified. Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: Unknown Context: 6 of 6 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation. Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. County policies have not been updated yet. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: This is a repeat finding. Prior year finding number was 2022-003. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.
Finding No.: 2023-001 Procurement Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.319 requires all procurement transactions to be conducted in a manner providing full and open competition. The Council’s purchasing and procurement policy requires the Council to obtain and evaluate competitive bids to determine the vendor with the optimal qualities including price, availability, and quality, among other factors; and the documentation of this process. Condition: The Council did not maintain documentation within 1 procurement file to demonstrate that the procurement was conducted in a manner providing full and open competition. Context: We selected a non-statistical sample of 2 procurement transactions out of a population of 6 procurement transactions, and noted that the procurement file for 1 of our selections included documentation of the significant history of the procurement transaction, however was missing specific documentation to evidence that the procurement was conducted in a manner providing full and open competition. Cause: The Council has adopted a purchasing and procurement policy which requires documentation of each procurement transaction to support that it was conducted in a manner providing full and open competition, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the purchasing and procurement policy resulted in a lack of evidence to support that a procurement transaction was conducted in a manner providing full and open competition. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. See Corrective Action Plan.
Finding No.: 2023-001 Procurement Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.319 requires all procurement transactions to be conducted in a manner providing full and open competition. The Council’s purchasing and procurement policy requires the Council to obtain and evaluate competitive bids to determine the vendor with the optimal qualities including price, availability, and quality, among other factors; and the documentation of this process. Condition: The Council did not maintain documentation within 1 procurement file to demonstrate that the procurement was conducted in a manner providing full and open competition. Context: We selected a non-statistical sample of 2 procurement transactions out of a population of 6 procurement transactions, and noted that the procurement file for 1 of our selections included documentation of the significant history of the procurement transaction, however was missing specific documentation to evidence that the procurement was conducted in a manner providing full and open competition. Cause: The Council has adopted a purchasing and procurement policy which requires documentation of each procurement transaction to support that it was conducted in a manner providing full and open competition, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the purchasing and procurement policy resulted in a lack of evidence to support that a procurement transaction was conducted in a manner providing full and open competition. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. See Corrective Action Plan.
2023-001 Procurement, Suspension and Debarment Information on the Federal Program: Program Name: Congressional Appropriations Program Federal Agency: United States Department of Treasury AL Number/Name: 21.U01 NeighborWorks® System Program FY 2023 Appropriation Criteria: According to 2 CFR § 200.318(a), General Procurement Standards, the non-Federal entity must have and use documented procurement procedures, consistent with State and local laws and regulations, 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 the Uniform Guidance. In addition, 2 CFR §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. All procurement transactions must be conducted in a manner providing full and open competition consistent with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. Furthermore, 2 CFR §200.320(c), Noncompetitive Procurement, states that 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. Condition: During our review of the Corporation’s procurement policies, we noted that the Corporation’s written internal procurement policies and procedures during the first quarter of fiscal year 2023 are not in conformity with the requirements identified in the Uniform Guidance procurement requirements. During our testing of the procurement, suspension and debarment compliance requirement, we selected 10 procurement samples for testing. We noted that 2 out of the 10 procurement samples were procured by way of a noncompetitive proposal process through a solicitation from only one source under the criteria of either: (1) the item is available only from a single source or (2) there is an urgent and compelling need for the goods or services. However, based on our review of the 2 procurement files, we noted that the 2 procurement files do not appropriately justify the use of a noncompetitive procurement process due to the following reasons: 1. The supplies or services being procured are sold or provided by other vendors, not just by a single source. 2. Incumbency of the vendor is not a valid noncompetitive procurement justification. 3. Contracting without providing for full and open competition shall not be justified on the basis of (1) lack of advance planning by the requiring activity; or (2) concerns related to the amount of funds available for the acquisition of supplies or services. Cause: The Corporation’s personnel did not adhere to the federal requirements and the Corporation’s internal procurement policies and procedures particularly on the use of noncompetitive procurements. Effect: Failure to perform procurement procedures in accordance with the Corporation’s documented policies and the procurement procedures under the Uniform Guidance procurement requirements could result in expenditures incurred being disallowed. Questioned Costs: Not determinable. Context: This is a condition identified per review of the Corporation’s compliance with the specified requirements using a non-statistical sample. The total federal expenditures related to the 2 noncompetitive procurements is $105,985 for the year ended September 30, 2023. The total contract value of the 2 noncompetitive procurements is $430,000 with contract terms that ranges from 6 months to 4 years. The total federal expenditures for all of the 10 procurement samples selected for testing is $2,472,158 for the year ended September 30, 2023. Repeat Finding: This is a repeat finding of 2022-001. Recommendation: We understand that the Corporation updated its procurement policies and procedures in March 2023 to conform with the requirements identified in the Uniform Guidance procurement requirements. We recommend that the Corporation should ensure that the use of Noncompetitive Procurement criteria under the Uniform Guidance procurement requirements are adhered to and appropriate justifications for these contracts are used and documented appropriately. In addition, the Corporation should continue to use the system in place to track and monitor the terms of vendor contracts in order to plan in advance if the contracts will need to be subject to a competitive procurement process providing full and open competition as required. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-004: Procurement Information About the Program: All Programs Criteria: According to 2 CFR §200.303, 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). Additionally, according to 2 CFR §200.318 Procurement standards, 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. Title 2, Subtitle A Chapter II Part 200 Subpart D 200.319 Procurement Standards. All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2 CFR §200.320 Procurement Standards, 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 (see paragraph (a)(1) of this section); 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. Condition: During our testing over procurement, we determined NFHA did not clearly document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, for noncompetitive procurements, there was no documentation to support which of the five criteria was met to allow for the noncompetitive procurement. Cause: Management did not have effective internal controls in place to ensure that procurement requirements were adequately documented and retained. Effect: Procurement records were insufficient to meet the requirements noted in the Criteria section above, as well as NFHA's internal procurement policy. Questioned Costs: None. Context: We noted that several items selected for testing did not document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, we noted that several items selected for testing for noncompetitive procurements did not maintain documentation of which of the five criteria were met to allow for the noncompetitive procurement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend NFHA update its policies to treat Federal and non-Federal procurement the same and ensure compliance with Uniform Guidance. NFHA should retain sufficient procurement documentation to meet the requirements noted in the Criteria section above.