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.
Criteria: In accordance with 2 CFR 200.320, the City of Carencro is required to formally bid contracts that exceed $250,000. Condition: The City expended $142,051 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not put out for bid. Cause: The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect: As a result, the City was not in compliance with procurement requirements with questioned costs totaling $142,051. Context: A sample of 10 disbursements were selected for audit from a population of 16 disbursements. The test found that a vendor was not properly procured. This resulted in questioned costs of $142,051. Recommendation: The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan: This compliance finding relates to the previous administration, who did not properly have the vendor bid out in accordance with federal guidelines. The City will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
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.
Procurement in Compliance with Uniform Guidance Federal Program Information: Funding agency: U.S. Department of the Treasury Title: COVID-19 - State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: In accordance with 2 CFR §200.320, the auditee is responsible for following its procurement procedures provided that the procedures conform to applicable Federal Statutes and the procurement requirements identified in 2 CFR §200.320. Condition: During major program testing, auditors inquired about the County’s procurement procedures. The County does not have a written procurement policy, and therefore is not in compliance with Uniform Guidance. Context: There is no written procurement policy in accordance with Uniform Guidance being followed. Questioned Costs: None Effect: The County could expend federal funds on equipment or capital assets without getting the proper quotes or approvals. Cause: There is no written procurement policy in accordance with Uniform Guidance being followed. Repeat: Yes Auditor's Recommendation: We recommend the County adopt a written procurement policy in accordance with the Uniform Guidance and provide the policy to each department that expends federal awards. View of Responsible Officials: We agree with the finding and have developed a corrective action plan.
Criteria: In accordance with 2 CFR 200.320, the City of Carencro is required to formally bid contracts that exceed $250,000. Condition: The City expended $142,051 of Coronavirus State and Local Fiscal Recovery Funds on a contract that exceeded the required threshold but was not put out for bid. Cause: The City expended federal funds on contracts that were not properly bid by federal guidelines. Effect: As a result, the City was not in compliance with procurement requirements with questioned costs totaling $142,051. Context: A sample of 10 disbursements were selected for audit from a population of 16 disbursements. The test found that a vendor was not properly procured. This resulted in questioned costs of $142,051. Recommendation: The City should review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320. Management’s Corrective Action Plan: This compliance finding relates to the previous administration, who did not properly have the vendor bid out in accordance with federal guidelines. The City will review their policies and procedures to ensure that all contracts that have federal expenditures are properly bid in accordance with 2 CFR 200.320.
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.
Procurement in Compliance with Uniform Guidance Federal Program Information: Funding agency: U.S. Department of the Treasury Title: COVID-19 - State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: In accordance with 2 CFR §200.320, the auditee is responsible for following its procurement procedures provided that the procedures conform to applicable Federal Statutes and the procurement requirements identified in 2 CFR §200.320. Condition: During major program testing, auditors inquired about the County’s procurement procedures. The County does not have a written procurement policy, and therefore is not in compliance with Uniform Guidance. Context: There is no written procurement policy in accordance with Uniform Guidance being followed. Questioned Costs: None Effect: The County could expend federal funds on equipment or capital assets without getting the proper quotes or approvals. Cause: There is no written procurement policy in accordance with Uniform Guidance being followed. Repeat: Yes Auditor's Recommendation: We recommend the County adopt a written procurement policy in accordance with the Uniform Guidance and provide the policy to each department that expends federal awards. View of Responsible Officials: We agree with the finding and have developed a corrective action plan.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
2023-002 – PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: State Humanities Program and Humanities Councils American Rescue Plan Funding AL #: 45.129 Award #s: ZSO-283159-21 ARP, SO-268668-20 and SO-289867-23 Award Period: November 1, 2022 – October 31, 2023 Questioned Costs: None Statement of Condition The Council did not consistently follow the suspension and debarment policy and did not keep backup documentation for some of the procurement transactions over $10,000. Context The Council purchased goods and services exceeding $25,000 and documentation was not available to substantiate that the vendors were screened for suspension and debarment prior to expenditure. Note: All the vendors were screened during the audit and none of them had any exclusions. Also, the Council had documentation for all 6 sub-awardees tested (non-procurement clause of the award.) Criteria Per 2 CFR 200.320(a)(2)(i) Small purchases - (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when the grantee enters into a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. While the Council has policies in place and links in the policies to the appropriate CFRs, it seems that the policies might need to be updated to specify the thresholds for debarment and suspension checks for vendor and the updated threshold for micro-purchasing. Cause The Council had turnover in employment for staff in charge of obtaining 3 bids and documentation could not be located. The policies might need to be updated with the new micro-purchasing thresholds and clearly specify the thresholds for vendor check-ups in sam.gov. Effect There is the risk that the Council could contract with a party that is suspended or debarred. The Council is not following consistently the policies. Recommendation Design and implement internal controls to ensure that contracts expected to equal or exceed $25,000, or meet certain other criteria as specified in 2 CFR 180.220, are checked for suspension and debarment. Improve the policies and procedures manual by updating the thresholds for micro-purchases and small purchases, and adding explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. View of Responsible Official and Corrective Action Plan: NMHC management is in agreement with this finding. Management has reviewed the existing federal procurement policies and procedures found in 2 CFR 200 and will enforce the policies and procedures to ensure existing suspension and debarment policies and procedures are followed. NMHC’s Executive Director or Deputy Director will review all potential purchases and contracts for compliance with the policies. The Executive Director or Deputy Director will also provide an additional check by reviewing all vendors paid $25,000 or more against the SAM website. Proof of the SAM website review and approval will be maintained in each vendor file. All future contracts of any size will also include a clause or condition to the covered transaction with the contractor/vendor that must be signed by that person. The Executive Director will update the existing NMHC policies and procedures manual by adding the new thresholds for micro-purchases and small purchases. The Executive Director will also add explicit reference to the $25,000 threshold for vendors under procurement regulations regarding debarment and suspension. Corrective Action Plan Timeline: Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline: Personnel responsible for ensuring implementation include the Executive Director and Deputy Director.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition – Management did not perform an appropriate form of competition for two purchases made within the small purchase threshold. Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed for the vendors during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold in the Code of Federal Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,666. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – This is a repeat finding as there was a procurement finding in the prior year. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented a new procurement policy effective January 2024 for all vendors where the vendors will have their own procurement documents. The chosen vendors can be the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be maintained on the Organization's server.
Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2023 Funding Criteria: Competitive Procurement: 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete when it makes sense regardless of the threshold and can be achieved by obtaining three quotes, i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition. CASIS may solicit a proposal from only one source in circumstances where one or more of the following conditions apply (FAR Subpart 6.3): (i) The item or service is available only from a single source. (ii) An unanticipated exigency or emergency exists that requires the equipment, materials, supplies or services to be procured immediately. (iii) NASA specifically authorizes the use of noncompetitive proposals (directed source). (iv) After consultation with a number of sources, competition is determined inadequate. (v) The vendor is listed as a sole source provider under the Cooperative Agreement. Vendor disbursements: 2 CFR section 200.214 and 2 CFR section 180.300 require non-federal entities restrict awards, subawards, and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Internal controls: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. - 10 - Condition: Competitive quotes were not obtained for one expense, and sole source determination was not documented for another expense. In addition, for one vendor there was no check performed to ensure it was not debarred prior to the purchase approval. Cause: For one expense, CASIS did not obtain competitive quotes as required per their policy. CASIS had used the venue for meetings in the past, and did not obtain additional quotes for this event. This is a control and compliance deficiency. For another expense tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. This expense is for a membership and essentially has a single provider. This is a control deficiency, but not a compliance issue. For one vendor, CASIS did not perform SAM check prior to approving the purchase. Vendor search at SAM.gov, subsequent to year end, revealed that the vendor is not debarred. This is a control deficiency, but not a compliance issue. Effect: If CASIS cannot demonstrate that procurements were made with full and open competition, properly sole sourced, and vendors are not debarred, it can result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $17,967, and likely questioned costs of $25,293. Perspective: For open competition there were 2 out of 60 expenses selected that the control failed. There was one vendor out of 10 selected that the debarment check was not performed. Recommendation: Competitive quotes should be obtained and retained as specified in the procurement policy. Non-competitive procurement should be documented and approved prior to incurring expenses. Vendor debarment checks should be performed and documented prior to entering into covered transactions. Management Response: The audit uncovered a non-compliance with required competitive quotes for a procurement of meeting services which did not comply with CASIS policy. The predecessor management team had previously advised the responsible purchaser that these services did not require competitive quotes. This matter is also complicated by the fact that the procurements are not just for meeting space, logistics and meals, but also includes lodging, which is not subject to the three quote rule. Management acknowledges that this was a process escapement and provides for the following corrective action. Typically lodging expenses are included in the procurement because it results in discounts that are unavailable if not included. CASIS implemented a policy of requiring competitive quotes for purchases over $1,000 in the most recent revision of the procurement policy. This change was made to assure compliance with Federal Regulations. While the amount noted is within the limits established by Federal Micro- purchase regulations, it did not comply with internal policies as noted. Meeting space is a commonly used service that is highly competitive in pricing and most facilities charge competitive rates, but most of the time those quotes are not useable given the time of year, and more importantly the occupancy rate of the facility. Starting in 2024, we are requesting quotes from three facilities in the local area that will be valid for a period of one year. These rates will be updated manually and a single additional quote will be obtained to assure the “reasonableness” of the price. This process will represent an annual price survey that will satisfy the three quote rule of our procurement policy. For rental of facilities outside of the local area, we will obtain a minimum of three quotes as required by our procurement policy. Management also acknowledges the process escapement for SAM checks on new vendors. Our normal process is that annually, Finance performs a SAM check for all approved vendors. The agreement for Trust Factory came in late during the year resulting in this deficiency. When a new vendor is setup in our system, it will automatically trigger a SAM check.
2023-02 – Procurement, Suspension and Debarment Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance. Program. COVID-19 - State and Local Fiscal Recovery Funds (CSLFRF); U.S. Department of Treasury; Assistance Listing Number 21.027 Criteria. Recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. For the one vendor tested that had expenditures of $2,256,725, the County was unable to provide documentation to support that competitive bidding was performed in accordance with the County's policies and procedures. Cause. This condition was caused by management oversight. Effect. As a result of this condition, the procurement requirements as outlined within the County's policy were not followed. Questioned Costs. The total charges included in our sample that were not supported by appropriate documentation amounted to $2,256,725. Recommendation. We recommend that the County follow their policies and retain documentation to support those policies are abided by. View of Responsible Officials. Management recognizes and agrees with the recommendations of the auditors. The costs were allowable under the CSLFRF with respect to the eligible use of funds. The County has a "Policies and Procedures of Federal Awards Administration" outlining the requirement for purchases made with federal funds. The County had an existing project development agreement with a vendor to conduct a preliminary evaluation of the County's facilities and energy costs. It is management's view the County should have provided the sole source justification form for use of the vendor for implementation of the project with the reason indicated as it was currently under contract through a November 17, 2021, Resolution (#21-11-119 to Approve Energy and Infrastructure Project Development Agreement) rather than rely upon the resolution as the basis for the sole source non-competitive proposals. Management intends to follow the existing policy in its entirety, but will recommend changes to procedures to ensure compliance with purchasing policies. These changes to procedures will be recommended on the basis that simplification of the process is important since the use of sole sourcing of vendors is intended to occur on an infrequent basis. Responsible Official. Connie Sobie, Controller/Administrator Estimated Completion Date. September 30, 2024.
Reference Number: 2023-001 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: None Compliance Impact: Material Noncompliance AL Number and Title: 84.425 - COVID-19 Education Stabilization Fund Federal Awarding Agency: U. S. Department of Education Federal Award Number: None Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $1,029,533.57 Items purchased were not competitively bid in accordance with Procurement and Suspension/Debarment requirements. Finding The U.S. Code of Federal Regulations Title 2, Part 200.318, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must have and use its own documented procurement procedures which reflect State and local laws and regulations provided that the procurements conform to applicable Federal law and the standards identified within that section. The Code of Alabama 1975, Title 39, which is a State law, requires the construction, installation, repair, renovation of public buildings in excess of $50,000.00 that are paid, in whole or part, with public funds to be bid under the provisions of the Public Works Law. In addition, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2CFR 200.320, states that when the aggregate dollar amount is higher than the simplified acquisition threshold ($250,000.00), the Uniform Guidance requires one of the two “formal procurement methods”, sealed bids or formal request for proposals should be used. The Blount County Board of Education (the “Board”) entered a Public Works contract in November 2021 for the purchase and installation of HVAC units at multiple local schools totaling $1,576,971.00 of which $1,029,533.57 of COVID-19 Education Stabilization Funds were expended during the audit period, The Board did not obtain bids on the project in accordance with the State of Alabama Public Works Law. The Board used a purchasing consortium contract which is not allowed under the Public Works Law or the procurement guidelines contained in the Uniform Guidance for purchases greater than the simplified acquisition threshold. As a result, the Board did not comply with Uniform Guidance procurement requirements for these purchases. Recommendation: The Board should ensure compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Views of Responsible Officials of the Auditee The Board agrees with the finding.
Reference Number: 2023-001 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: None Compliance Impact: Material Noncompliance AL Number and Title: 84.425 - COVID-19 Education Stabilization Fund Federal Awarding Agency: U. S. Department of Education Federal Award Number: None Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $1,029,533.57 Items purchased were not competitively bid in accordance with Procurement and Suspension/Debarment requirements. Finding The U.S. Code of Federal Regulations Title 2, Part 200.318, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must have and use its own documented procurement procedures which reflect State and local laws and regulations provided that the procurements conform to applicable Federal law and the standards identified within that section. The Code of Alabama 1975, Title 39, which is a State law, requires the construction, installation, repair, renovation of public buildings in excess of $50,000.00 that are paid, in whole or part, with public funds to be bid under the provisions of the Public Works Law. In addition, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2CFR 200.320, states that when the aggregate dollar amount is higher than the simplified acquisition threshold ($250,000.00), the Uniform Guidance requires one of the two “formal procurement methods”, sealed bids or formal request for proposals should be used. The Blount County Board of Education (the “Board”) entered a Public Works contract in November 2021 for the purchase and installation of HVAC units at multiple local schools totaling $1,576,971.00 of which $1,029,533.57 of COVID-19 Education Stabilization Funds were expended during the audit period, The Board did not obtain bids on the project in accordance with the State of Alabama Public Works Law. The Board used a purchasing consortium contract which is not allowed under the Public Works Law or the procurement guidelines contained in the Uniform Guidance for purchases greater than the simplified acquisition threshold. As a result, the Board did not comply with Uniform Guidance procurement requirements for these purchases. Recommendation: The Board should ensure compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Views of Responsible Officials of the Auditee The Board agrees with the finding.
Reference Number: 2023-001 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: None Compliance Impact: Material Noncompliance AL Number and Title: 84.425 - COVID-19 Education Stabilization Fund Federal Awarding Agency: U. S. Department of Education Federal Award Number: None Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $1,029,533.57 Items purchased were not competitively bid in accordance with Procurement and Suspension/Debarment requirements. Finding The U.S. Code of Federal Regulations Title 2, Part 200.318, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must have and use its own documented procurement procedures which reflect State and local laws and regulations provided that the procurements conform to applicable Federal law and the standards identified within that section. The Code of Alabama 1975, Title 39, which is a State law, requires the construction, installation, repair, renovation of public buildings in excess of $50,000.00 that are paid, in whole or part, with public funds to be bid under the provisions of the Public Works Law. In addition, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2CFR 200.320, states that when the aggregate dollar amount is higher than the simplified acquisition threshold ($250,000.00), the Uniform Guidance requires one of the two “formal procurement methods”, sealed bids or formal request for proposals should be used. The Blount County Board of Education (the “Board”) entered a Public Works contract in November 2021 for the purchase and installation of HVAC units at multiple local schools totaling $1,576,971.00 of which $1,029,533.57 of COVID-19 Education Stabilization Funds were expended during the audit period, The Board did not obtain bids on the project in accordance with the State of Alabama Public Works Law. The Board used a purchasing consortium contract which is not allowed under the Public Works Law or the procurement guidelines contained in the Uniform Guidance for purchases greater than the simplified acquisition threshold. As a result, the Board did not comply with Uniform Guidance procurement requirements for these purchases. Recommendation: The Board should ensure compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Views of Responsible Officials of the Auditee The Board agrees with the finding.
2023-002 Procurement U.S. Department of the Treasury ALN 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Fund Contract No. Y5283 FL0283 (2021) Criteria: 2 CFR Sections 202.303(a) and 200.320 set forth the requirements to establish and maintain effective internal controls over federal awards and for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. The City’s Financial & Budget Operational Guidelines specify that purchases over $25,000 must go through a formal bid and proposal process. In addition, the City’s practice is to obtain three quotes for purchases between $5,000 and $25,000. Condition: Competitive quotes and/or bids were not appropriately obtained for purchases from two vendors. These purchases, however, were beneath the Simplified Acquisition Threshold required by Uniform Guidance. Cause of condition: The vendors were established vendors of the City selected for continuity of service and for their ability to obtain identical materials as previously used by the City. As a result, the City inadvertently exceeded procurement thresholds. Questioned costs: Known questioned costs $140,644. We calculated these costs by identifying all award expenses with vendors not subjected to competitive procurement practices. Perspective (context): We noted competitive procurement was not followed for three of the 40 expenses tested, representing two (2) different vendors (out of 14 vendors). The costs associated with these purchases were allowable costs for activities allowed under the grant program, confining the issue to procurement. While the City did not document competitive quotes for these purchases, we did not note any misuse of grant funds. Potential effect of condition: The City did not comply with Federal compliance requirements or City policies established to promote competition and make the procurement process more transparent. Recommendation: Competitive quotes should be obtained and retained as specified in the City’s procurement policies and Uniform Guidance. Non-competitive procurement (for sole source vendors) should be documented and approved prior to incurring expenses. The City should update and expand procurement policies to document competitive procurement practices for procurement less than the bid threshold Management’s response on planned corrective action: Staff have already implemented a procurement policy to attach all the quotes received from vendors to the purchase order. In the future when reviewing, staff will be able to see all the vendors that provided a quote and see the lowest quote was used to procure the item(s).
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 2023-003: Use of Sole-Sourced Justification for Procurement Federal Programs: All ProgramsCriteria: Under Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Section 200.320(f) “Methods of procurement to be followed”, procurements by noncompetitive proposals (i.e. sole-sourced justification) may be used only when one or more of the following circumstances apply: The item is available only from a single source; The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or After solicitation of a number of sources, competition is determined inadequate. Condition: Our audit work over various expenses disclosed instances of consultants and vendors hired under the sole-sourced justification method of procurement. Although the expenses were properly supported, the rationale for several sole-sourced selections was not properly documented and/or not always appeared to be reasonable. Cause: The Consolidated Entity was not in full compliance with sole-sourced justification requirements, as stated above, during the year ended September 30, 2023. Effect or Potential Effect: The Consolidated Entity could enter into contractual arrangements whereby they are not receiving the best value for the organization and/or in which there exists conflicts of interest. Ultimately, transparency with respect to these transactions could be compromised if the proper procurement actions are not followed. Questioned Costs: None noted. Context: The Consolidated Entity failed to consistently document its justification with respect to solesourced according to the above-noted requirements. Identification as a Repeat Finding: 2022-004 Recommendation: We recommend that the Consolidated Entity limit its use of sole-sourced justification based on the above-noted requirements. In cases where sole-sourced is appropriate, we recommend that the actions (or lack of actions) be properly and fully documented. The importance in maintaining a record of each procurement action is to support the Consolidated Entity’s due diligence process. We also believe this process helps identify any actual or potential conflicts of interest with prospective vendors and contractors.