Finding 2024-004 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement Identification of the federal program Agencies Award Numbers ALN 15.022 Tribal Self Governance ` Department of Interior GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Criteria The Uniform Guidance in 2 CFR Section 200.320(b), Procurement Methods – Small Purchase, is required if the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Unless specified by the Federal agency, the recipient or subrecipient may exercise judgment in determining what number is adequate. The recipient or subrecipient is responsible for determining an appropriate small purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures, which may be lower than, but must not exceed, the threshold established in the Federal Acquisition Regulation. Condition The Association is not consistently following their own internal control policy for purchases that meet their small purchase threshold for procurement to obtain price or rate quotations from an adequate number of qualified sources. Cause AVCP is subject to high turnover in its purchasing department. Due to the frequency of new personal onboarding, the small purchase policy was missed was certain contracts. Effect or possible effect The Association not adhering to its established procedures, can lead to noncompliance, questioned costs, repayment obligations, or loss of funding. Questioned Costs None Identified. Context 2 out of 5 vendors selected for testing were not procured for in accordance with AVCP’s policy. Identification as a Repeat Finding None. Recommendation We recommend AVCP implement additional internal controls to ensure AVCP’s internal procurement policies are being followed. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. Thorough training in AVCP’s procurement policies and procedures will be provided to departmental staff. AVCP will also hold an overall training of AVCP’s key and senior personnel by an outside expert in government procurement rules and regulations.
Finding 2025-002: Competitive Proposal Process for Dental Van Procurement (Significant Deficiency) Federal Program: FIP [93.526] Federal Agency: U.S. Department of Health and Human Services (HHS) Criteria: Federal regulations under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), specifically 2 CFR § 200.319(b) and § 200.320(b), require that all procurement transactions be conducted in a manner providing full and open competition. For a competitive proposal process, the organization must publicly advertise the procurement and include a clear and accurate description of the technical requirements and specifications for the goods or services to be procured. Furthermore, 2 CFR § 200.320(b)(2)(i) requires that proposals be evaluated and a selection made based on established evaluation criteria. These criteria must be clearly stated in the solicitation and must be used as the basis for the selection, ensuring that price is a factor but not the only one. Condition: The organization intended to use a competitive proposal process to procure a van. However, it failed to publicly advertise the request for proposals, limiting the pool of potential vendors to only those known to the organization. Additionally, the request for proposals did not include a complete and accurate list of specifications, nor did it include the evaluation and selection criteria that would be used to assess the proposals. While the organization did obtain three proposals and documented its rationale for selecting a vendor that was not the lowest bidder, the overall process did not meet the standards for full and open competition required by federal regulations. Questioned Costs: None Cause: The organization lacked a clear understanding of the specific requirements for a federal competitive proposal process. There were no written procedures or internal controls in place to ensure all required documentation and steps were followed. This oversight, combined with an over-reliance on informal practices, contributed to the noncompliance. Effect: The non-compliant procurement process increases the risk that the organization paid more than was necessary for the vehicle, which is an inefficient use of federal funds. Context: This procurement was for a significant asset for the program. While the organization has made an attempt to solicit proposals, the process was fundamentally flawed from the outset due to the lack of public advertising, incomplete specifications, and missing evaluation criteria. This is the first time the organization has procured a van with these funds, and the error was an oversight rather than an intentional act of noncompliance. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: The organization should immediately develop and implement a comprehensive procurement policy and procedures manual that fully aligns with 2 CFR Part 200. This manual should provide a detailed checklist for all procurement methods, including specific requirements for public advertising, developing clear specifications, and documenting the full evaluation process based on a set of pre-established criteria. Mandatory training on federal procurement regulations should be provided to all staff involved in federal awards management and procurement to ensure they understand the importance of compliance. Management Response: The organization acknowledges the finding. To address this, we are committing to develop and implement a comprehensive procurement policy and procedures manual that strictly aligns with requirements within the Uniform Guidance. This manual will include detailed checklists for all procurement methods, covering public advertising, clear specification development, and the use of pre-established, documented evaluation criteria, followed by mandatory training for all staff involved in procurement.
FINDING 2024-001 Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number or Year (or Other Identifying Number): Interim Financing Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The City did not have an effective system of internal controls over federal award requirements, including procurement and suspension and debarment. The City failed to properly design and implement internal controls, such as appropriate segregation of duties, to ensure compliance and detect or correct noncompliance in a timely manner. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Procurement - Small Purchases During the audit period, the City had six vendors with purchases under the $150,000 threshold that were considered simplified acquisition procurements and over the $10,000 threshold that was considered micro-purchase procurements. All six vendors were selected for testing, and for five of those vendors, the City could not provide the procurement history or the rationale for the method of procurement, the selection of vendor, or the basis for price. The total dollar amount spent with these five vendors during 2024 was $246,055. Procurement - Simplified Acquisitions During the audit period, the City had three vendors with purchases over the $150,000 threshold that were considered simplified acquisition procurements. All three vendors were selected for testing, and for two of those vendors, the City could not provide the procurement history or the rationale for the method of procurement, the selection of vendor, or the basis for price. The total dollar amount spent with these two vendors during 2024 was $2,654,999. Procurement - Policy Per Uniform Guidance, 2 CFR 200.318(a), a non-federal entity that receives federal funds must have and use documented procurement procedures that conform to applicable federal, state, and local laws and regulations. Additionally, state law, such as Indiana Code 5-22, prescribes specific procedures for purchasing supplies and services based on various dollar thresholds. The City did not provide a purchasing policy for review that included the applicable federal regulation, such as procedures to avoid the acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or services to be procured. Additionally, the City did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. Suspension and Debarment Prior to entering into subawards and covered transactions, recipients are required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (ELPS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The City failed to verify that vendors were not suspended or debarred prior to entering into covered transactions exceeding $25,000. Of the eight vendors tested, no documentation was provided to show that a check was performed against the EPLS or through other acceptable verification methods. The lack of internal controls and noncompliance was determined to be a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320(b) states in part: "Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance awards exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause The City's management was not aware of federal compliance requirements related to procurement and suspension and debarment. The City had not established or implemented the necessary internal controls and written policies to ensure purchases and contracts were administered in accordance with federal and state regulations. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure that the services obtained provided full and open competition or the basis of the price. In addition, the City cannot ensure the vendors paid were eligible to participate in federal programs. Any program funds the City used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Noncompliance with the provisions of federal statues, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City's management establish a proper system of internal controls to ensure expenditures made from federal awards use the appropriate procurement method and retain the documentation to support the procurement methods used in order to ensure compliance with the terms and conditions of the federal award. We recommended that management of the City establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into contracts or subawards. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for federal programs is retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR § 200.318 through 200.327 which describe specific procedures non-Federal entities must follow when entering into procurement transactions using Federal funds. 2 CFR § 200.320(b) provides formal procurement methods are required when the value of the procurement transaction under a Federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Formal procurement methods are competitive and require public notice. 2 CFR § 200.320(b) outlines two formal methods of procurement that are used for procurement transactions above the simplified acquisition threshold, which are (1) sealed bids and (2) competitive proposals. Further, 2 CFR § 200.318(i) indicates the non-Federal entity must maintain records sufficient to detail the history of procurement transaction. These records must include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Due to inadequate controls over the procurement process, for one out of three (33%) vendors examined during testing of the Coronavirus State and Local Fiscal Recovery Funds, the Village did not obtain sealed bids or competitive proposals before contracting with Arcadis G & M of Ohio to provide engineering services. Expenditures for these services funded with Coronavirus State and Local Fiscal Recovery Funds during 2024 totaled $403,969. Failure to obtain proposals from a variety of vendors may result in the Village not utilizing the most qualified vendor as well as further noncompliance with federal requirements. The Village should adopt procedures to help ensure records are maintained to document the history of the procurement, including the rationale for the purchase method, selection of vendors, cost/price analysis (if applicable) and the reason for limiting competition (if applicable).
2024-005 Procurement, Suspension and Debarment Federal Assistance Listing Numbers – 21.027 Federal Agency – Department of Treasury Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 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 this section and §200.320. The nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. All six of the transactions tested did not follow the required procedures in place. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is a repeat finding of 2023-004. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.
Internal Controls over Compliance and Compliance with Procurement Standards Information on the Federal Program: Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.029 Assistance Listing Name: COVID-19 - Coronavirus Capital Projects Fund Pass-through Award: Pass-through Entity Award Number Award Period District of Columbia CPFFN0167 November 21, 2023 through December 31, 2026 Criteria: 2 CFR Section §200.318(i) states, “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Per 2 CFR Section §200.319, “All procurement transactions for the acquisition of property or services under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320.” 2 CFR Section §200.324 stipulates that a non-Federal entity must perform a cost or price analysis for each procurement in excess of a minimum threshold. Additionally, 2 CFR Section §200.320(c) states in part, “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of [the defined] circumstances apply”. Condition: We noted there was insufficient documentation retained to support adherence to the required procurement policy and standards. Documentation was unable to be provided to support that cost or price analyses were performed and were conducted providing full and open competition. Additionally, for one procurement deemed noncompetitive by WWHS, none of the circumstances allowing noncompetitive procurement were met. Cause: WWHS’ internal controls over procurement did not fully operate as designed for the year ended December 31, 2024. WWHS did not maintain all required aspects of formal documentation as required by the applicable 2 CFR standards, was unable to provide evidence of full and open competition, and in one instance improperly elected noncompetitive procurement. Effect: We were unable to determine whether the value of procurements for goods or services that exceeded the micro-purchase threshold followed a proper formal procurement method in accordance with 2 CFR Sections §200.319, 320, and 324. Failure to perform procurement procedures in accordance with WWHS’ documented policies and General Procurement Standards as outlined in the 2 CFR Part 200 could result in the procurement being disallowed. Questioned costs: Not determinable Context: We selected a sample of 6 procurements by non-statistical methods, out of a population of 11 procurements. All procurements are related to eligible pre-award costs. WWHS was unable to provide sufficient formal procurement documentation to support full and open competition and performance of cost or price analysis for 4 out of 6 selected procurements. One of those samples was deemed noncompetitive by WWHS but did not meet the circumstances allowing noncompetitive procurement. The prevalence of these findings is detailed in the condition section above. Repeat finding: This is not a repeat finding. Recommendation: We recommend management refine their procurement tracking method by clarifying established policies and procedures to create more consistency throughout all WWHS purchase transactions. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy and that a standardized checklist is used for all purchase transactions. Finally, we recommend management train personnel involved in procurement transactions, including reviewer and approver, to adhere to the documented procurement procedures. View of Responsible Officials: The procurement referenced in this finding was completed in 2021 and was connected to the buildout of a new facility that was opened in 2023. The federal award used to ultimately fund the project was obtained in 2024, and thus the expenditures retroactively applied to the award. Management concurs with this finding and will ensure proper adherence to the procurement policy.
Failure to Conduct Competitive Procurement Procedures Criteria Per 2 CFR §§ 200.318–200.327, non-federal entities must conduct all procurement transactions in a manner providing full and open competition. Sole source procurement may only be used when one of the circumstances outlined in 2 CFR § 200.320(c) applies and is adequately documented in the procurement file. Condition The Organization procured services from contractors identified in the approved grant budget prior to award. However, no evidence was provided to demonstrate that a competitive procurement process was conducted in accordance with the Uniform Guidance. There was no documentation of a sole source justification or other exception permitting noncompetitive procurement. Cause The Organization did not conduct competitive procurement or maintain a documented sole source justification for 4 out of 7 contracts reviewed. Listing the contractor in the grant budget prior to award does not satisfy federal procurement requirements outlined in the Uniform Guidance. Effect Failure to conduct competitive procurement increases the risk of noncompliance with the Uniform Guidance and the possibility that funds are not used appropriately, potentially resulting in questioned costs. Questioned Costs No questioned costs were identified as a result of our procedures. Context/Sampling Seven procurement transactions were tested under the program. In four instances, the Organization did not follow federal procurement requirements. No evidence of competitive bidding or documented sole source justification was provided for these transactions. Recommendation We recommend that the Organization implement procedures to ensure compliance with the procurement standards in 2 CFR §§ 200.318–200.327 for all federally funded purchases, including those where a contractor is named in the grant budget. For future procurements, the Organization should either conduct a competitive bidding process or document and obtain approval for a sole source procurement as allowed under 2 CFR § 200.320(c). Management’s Corrective Action Planned Management accepts the recommendation and will ensure compliance with the procurement standards in 2 CFR §§ 200.318–200.327 for all federally funded purchases by either conducting a competitive bidding process or documenting and obtaining approval for a sole source procurement as allowed under 2CFR §200.320(c).
2024-004 COMPLIANCE AND INTERNAL CONTROL OVER PROCUREMENT – ARPA Assistance Listing: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: The American Rescue Plan Act (ARPA) provided significant funding to state, local, and tribal governments to address the public health and economic impacts of the COVID-19 pandemic. These funds are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), which include the specific standards under Public Bid Law. Condition: For the year ended December 31, 2024, twelve vendors with expenditures totaling $ 2,179,730 were selected for testing. We noted for one of the vendors selected for testing, the City was unable to provide any contract or bid support for the project, which incurred $434,190 of expenditures during the year. Universe/Population: The total population for procurement considerations was all vendors of the American Rescue Plan Act whose transactions for the year ended December 31, 2024, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-three vendors totaling $2,790,345. Sample size : A sample of 12 vendors were selected for testing based on those with total expenditures over $10,000 during the fiscal year. Cause: The City did not adhere to compliance with Uniform Guidance Federal regulations per 2 CFR section 200.320 and its established procurement policy. The City did not maintain appropriate records needed to evidence compliance with Bid Law requirements. Effect: The City may enter into contracts with vendors that do not provide the best possible price when using public funds. Questioned Costs: For the purposes of this finding, there were no questioned costs. Recommendation: The City should strengthen controls to ensure appropriate consideration to competitors is given and adequate documentation is maintained with respect to procurement in accordance with federal Uniform Guidance requirements. Management’s response: The City concurs with the finding described above.
2024-004 COMPLIANCE AND INTERNAL CONTROL OVER PROCUREMENT – ARPA Assistance Listing: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: The American Rescue Plan Act (ARPA) provided significant funding to state, local, and tribal governments to address the public health and economic impacts of the COVID-19 pandemic. These funds are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), which include the specific standards under Public Bid Law. Condition: For the year ended December 31, 2024, twelve vendors with expenditures totaling $ 2,179,730 were selected for testing. We noted for one of the vendors selected for testing, the City was unable to provide any contract or bid support for the project, which incurred $434,190 of expenditures during the year. Universe/Population: The total population for procurement considerations was all vendors of the American Rescue Plan Act whose transactions for the year ended December 31, 2024, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-three vendors totaling $2,790,345. Sample size : A sample of 12 vendors were selected for testing based on those with total expenditures over $10,000 during the fiscal year. Cause: The City did not adhere to compliance with Uniform Guidance Federal regulations per 2 CFR section 200.320 and its established procurement policy. The City did not maintain appropriate records needed to evidence compliance with Bid Law requirements. Effect: The City may enter into contracts with vendors that do not provide the best possible price when using public funds. Questioned Costs: For the purposes of this finding, there were no questioned costs. Recommendation: The City should strengthen controls to ensure appropriate consideration to competitors is given and adequate documentation is maintained with respect to procurement in accordance with federal Uniform Guidance requirements. Management’s response: The City concurs with the finding described above.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non- Federal entities to follow documented procedures that promote full and open competition. For small purchases between $10,000 and $250,000, price or rate quotations must be obtained from at least three qualified sources. Purchases exceeding $250,000 must undergo formal procurement procedures such as sealed bidding or competitive proposals. Condition: During our testing of procurement transactions, we identified two vendors with individual purchases exceeding the small purchase threshold of $10,000 for which no documentation of competitive quotes was obtained. Additionally, one vendor exceeded the $250,000 threshold for which a formal competitive procurement process, such as sealed bids or proposals, was not conducted. Cause: While the Organization had a procurement policy aligned with federal requirements, the policy was not effectively enforced throughout the year. Possible effect: The Organization risked overpaying for goods or services and may not have achieved the best value for federal expenditures. Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors during fiscal year 2024. Recommendation: We recommend the Organization enhance its internal controls over procurement by implementing a pre-procurement review process and staff training to ensure consistent compliance with federal procurement thresholds and documentation requirements. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure procurement compliance.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
2024-002 Procurement Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2024 Funding, Repeat Finding Criteria: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. 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. 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. Condition: Sole source determination was not documented for two vendors. Cause: For two legal expenses tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. Effect: If CASIS cannot demonstrate that procurement of services were properly sole sourced, this may result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $41,762 and likely questioned costs of $90,024. Perspective: There were 2 out of 60 expenses selected for which the control failed. Recommendation: Non-competitive procurement should be documented and approved prior to incurring expenses. Management Response: CASIS acknowledges the error documenting these procurements. The two legal service vendors had been discussed internally and the selections rationalized based on the specialty of the professional services required for leasing and employment matters. Unfortunately, the documentation was not completed and stored as required by our internal policies. We consider these costs to be both necessary and reasonable, as we were negotiating a new office space lease and the rates were consistent with other legal service providers that CASIS has procured. CASIS plans on reinforcing the procurement documentation requirements with our personnel through additional training and reminding that engagement letters need to go through our document review software.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Reference Number: 2024-002 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance AL Number(s) and Title(s): 10.553 and 10.555 – Child Nutrition Cluster Federal Awarding Agency: U.S. Department of Agriculture Federal Award Number: 255AL322N1199 Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $62,778.22 Child Nutrition Cluster funds were used to pay $62,778.22 for services and supplies without obtaining required quotes. The U. S. Code of Federal Regulations Title 2, Part 200.320(a), of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that the recipient or subrecipient is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. The Board’s documented procurement procedures state that the procurement transactions for federal programs and child nutrition programs that are not subject to the state procurement laws but exceed the aggregate amount of the federal micro-purchase threshold of $10,000 will be obtained by utilizing price or rate quotes from two or more qualified sources. Septic tank services, equipment maintenance/repair services, and kitchen supplies in the amount of $62,778.22 were paid from Child Nutrition Cluster funds. The Board failed to obtain price or rate quotes from an adequate number of qualified sources during the audit period. As a result, the Board failed to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a). Recommendation: The Board should comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.320 by following its documented procurement procedures. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Reference Number: 2024-002 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance AL Number(s) and Title(s): 10.553 and 10.555 – Child Nutrition Cluster Federal Awarding Agency: U.S. Department of Agriculture Federal Award Number: 255AL322N1199 Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $62,778.22 Child Nutrition Cluster funds were used to pay $62,778.22 for services and supplies without obtaining required quotes. The U. S. Code of Federal Regulations Title 2, Part 200.320(a), of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that the recipient or subrecipient is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. The Board’s documented procurement procedures state that the procurement transactions for federal programs and child nutrition programs that are not subject to the state procurement laws but exceed the aggregate amount of the federal micro-purchase threshold of $10,000 will be obtained by utilizing price or rate quotes from two or more qualified sources. Septic tank services, equipment maintenance/repair services, and kitchen supplies in the amount of $62,778.22 were paid from Child Nutrition Cluster funds. The Board failed to obtain price or rate quotes from an adequate number of qualified sources during the audit period. As a result, the Board failed to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a). Recommendation: The Board should comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.320 by following its documented procurement procedures. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Congressional Appropriations Program, Public Law '118.420 Assistance Listing Number: 21.U01 NeighborWorks System Program FY 2024 Appropriation Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Corporation should have internal controls designed to ensure compliance with those provisions. In addition, 2 CFR Part 200.320(c) states that there are specific circumstances in which the recipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: (1) The aggregate amount of the procurement transaction does not exceed the micro-purchase; (2) The procurement transaction can only be fulfilled by a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; (4) The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or (5) After soliciting several sources, competition is determined inadequate. Condition: During our testing, we noted two procurement samples were procured by way of a noncompetitive proposal process through a solicitation from only one source that did not meet the circumstances of 2 CFR Part 200.320(c). The sole source justifications that were documented in the procurement files for these two samples were not in compliance with the Uniform Guidance. Questioned costs: Not determinable Context: We selected samples from three populations of vendors who had federal expenses in fiscal year 2024 based on when the procurements were completed. The two exceptions were from the population of procurements completed prior to March 2023. These procurements were completed in February 2020 and July 2022, respectively. Total federal expenditures related to these procurements were $194,571 during fiscal year 2024 and the total award amounts were $1,035,000. We did not identify exceptions in our testing of procurements completed March 2023 or after. Cause: Prior to fiscal year 2024, at the time these procurements were performed, the Corporation’s procurement policy allowed sole source justifications that were not compliant with the Uniform Guidance. Effect: The Corporation incurred federal expenses during fiscal year 2024 under procurements that did not comply with the requirements of the Uniform Guidance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend the Corporation ensure controls are in place so that expenses charged to federal programs are in compliance with the procurement requirements of the Uniform Guidance. As part of this, the Corporation should consider identifying active contracts that were improperly procured and determine actions to correct the noncompliance. Views of responsible officials: There is no disagreement with the audit finding.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.