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 As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified.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.
Program Information: Cluster: Research and Development Cluster Federal Program: Child Health and Human Development Extramural Research ALN: 93.865 Federal Agency: United States Department of Health and Human Services Pass-through entity: N/A Grant Name(s): Influence of Maternal Virome and HIV Status on Infant Gut Virome, Growth, and Immunity; Influence of HIV Infection on Vaginal Virome and Risk of Preterm Birth in Pregnant South African Women Grant ID Number Federal Award Year 5R01HD102239-04 9/21/2020 – 8/30/2025 5R01HD106821-04 9/9/2021 – 7/31/2026 Criteria or requirement: Per 2 CFR 200.320(a)(2)(i): Simplified acquisition procedures. The aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If simplified acquisition 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. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: For 2 out of 40 procurement selections tested, totaling $22,675, the entity did not obtain price or rate quotations as required by its procurement policies. Both selections, related to the same purchase invoice, were above the micro-purchase threshold and were related to cost transfers to federal awards. Cause and possible asserted effect: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement policies. Identification of questioned costs and how they were computed: Known questioned costs identified as part of this finding were $22,675. Sample Statistically Valid: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding from prior year: No Recommendation: We recommend that management design and implement a control to review cost transfers to federal awards to ensure that the entity follows its procurement policies. Views of Responsible Officials: Management will design and implement a control to review cost transfers from non-federal awards to federal awards to ensure we follow our procurement policies. This will be achieved by adding a new step to the non-payroll cost transfer form that requires the requestor to include a copy of the Procurement authorization form if the procurement policies apply. The Procurement authorization form documents the process, rationale, and justification for procurements. If the purchase being transferred did not go through the appropriate procurement procedures at the time of purchase, then the transfer from the non-federal award to the federal award will not be allowed. Management will also provide additional training around procurement and our related policies and ensure staff involved in this area are aware of the new step embedded in the non-payroll cost transfer form.
Program Information: Cluster: Research and Development Cluster Federal Program: Child Health and Human Development Extramural Research ALN: 93.865 Federal Agency: United States Department of Health and Human Services Pass-through entity: N/A Grant Name(s): Influence of Maternal Virome and HIV Status on Infant Gut Virome, Growth, and Immunity; Influence of HIV Infection on Vaginal Virome and Risk of Preterm Birth in Pregnant South African Women Grant ID Number Federal Award Year 5R01HD102239-04 9/21/2020 – 8/30/2025 5R01HD106821-04 9/9/2021 – 7/31/2026 Criteria or requirement: Per 2 CFR 200.320(a)(2)(i): Simplified acquisition procedures. The aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If simplified acquisition 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. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: For 2 out of 40 procurement selections tested, totaling $22,675, the entity did not obtain price or rate quotations as required by its procurement policies. Both selections, related to the same purchase invoice, were above the micro-purchase threshold and were related to cost transfers to federal awards. Cause and possible asserted effect: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement policies. Identification of questioned costs and how they were computed: Known questioned costs identified as part of this finding were $22,675. Sample Statistically Valid: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding from prior year: No Recommendation: We recommend that management design and implement a control to review cost transfers to federal awards to ensure that the entity follows its procurement policies. Views of Responsible Officials: Management will design and implement a control to review cost transfers from non-federal awards to federal awards to ensure we follow our procurement policies. This will be achieved by adding a new step to the non-payroll cost transfer form that requires the requestor to include a copy of the Procurement authorization form if the procurement policies apply. The Procurement authorization form documents the process, rationale, and justification for procurements. If the purchase being transferred did not go through the appropriate procurement procedures at the time of purchase, then the transfer from the non-federal award to the federal award will not be allowed. Management will also provide additional training around procurement and our related policies and ensure staff involved in this area are aware of the new step embedded in the non-payroll cost transfer form.
2024-001: PROCUREMENT, SUSPENSION, AND DEBARMENT Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.788 Opioid STR Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, either formal procurement methods, or documentation of noncompetitive procurement, are required. Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not document the noncompetitive procurement process pursuant to 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Cause/Effect: Management oversight. Questioned Cost: None Context: Due to an immediate, unexpected need for specialized services, the CMHSP entered into a contract with a vendor established with the PIHP, but did not document the noncompetitive procurement process pursuant to 2 CFR 200.320. Also, upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that formal procurement methods are documented and verification of suspension, debarment, or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
Criteria: Per the Uniform Guidance at 2 CFR 200.320, purchases classified as a “simplified acquisition” are those with an aggregate dollar amount above the micro-purchase threshold but below the simplified acquisition threshold determined by either the State Bid Law or Uniform Guidance; whichever is more restrictive. If “simplified acquisition” procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Adequate controls were not in place to ensure that procedures for purchases classified as a “simplified acquisition” are being followed. Cause and effect: Lack of policies and procedures for purchases that fall under the classification of “simplified acquisition” led to the noncompliance with Uniform Guidance 2 CFR 200.320. Identification of repeat finding: This is not a repeat finding. Recommendation: The City should adopt policies and procedures and improve controls to ensure that procurement requirements for federal awards are being met. View of responsible officials: The City concurs – see corrective action plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), 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. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
Program Information: U.S. Department of the Interior Single Agreement – Assistance Listing #15.036 Award Number: A18AV00341 Award Period: 10/01/2023 – 9/30/2024 Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Per 2 CFR § 200.303 Internal controls, 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). Condition/Context: 1 of 3 procurement samples selected for testing had no documentation of bidding, alternative price quotes, or sole source documentation. Additionally, for 1 of 1 Individually Important Items and 2 of 2 suspension and debarment samples selected for testing, NWIFC could not provide support showing a SAM.gov check was performed prior to conducting business with the vendors. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: It appears the policies and procedures for procurement and suspension and debarment were not followed. Effect: Without solicitation from an adequate number of qualified sources, NWIFC is at risk of over-spending on projects and, thus, leaving fewer resources available to fulfill the mission of NWIFC. Additionally, NWIFC could be subject to other sanctions from funding agencies if they determine that programs did not assure vendors were properly checked for suspension and debarment. Questioned Costs: $25,750 for procurement. This amount represents procurement transactions selected for testing that lacked required documentation of competitive bidding, price comparisons, or sole source justifications. As a result, these costs do not meet the allowability and procurement standards under 2 CFR 200.318–200.320 and are therefore questioned. Not applicable for suspension and debarment. While internal controls were not followed, no specific transactions were identified that violated the cost allowability requirements. Repeat Finding: Yes, finding #2023-003. Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Finding Number: 2024-010 Prior Year Finding Number: N/A Compliance Requirement: Procurement and Suspension and Debarment Program: U.S. Department of the Treasury COVID-19 – Coronavirus Capital Projects Fund ALN: 21.029 Award #: CPFFN0167 Award Year: 02/09/2022 – 12/31/2026 Government Department/Agency: District of Columbia Public Library (DCPL) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, 2 CFR Section 200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with 2 CFR Section 200.319 and must be performed using the appropriate procurement method as outlined in 2 CFR Section 200.320. In accordance with 2 CFR Section 200.320(c), Noncompetitive procurement. There are specific circumstances in which the recipient or subrecipient 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 threshold (see paragraph (a)(1) of this section); (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 of procurement and suspension and debarment requirements, we examined the two (2) procurement contracts that comprised the entire procurement population. Based on the procedures performed, we identified one (1) contract, valued at $278,259, out of the two (2) contracts totaling $8,185,708, in which DCPL used a single source or sole source justification for the selection rationale. However, this justification did not comply with the requirements set forth in 2 CFR Section 200.320(c). Questioned Costs – Not determinable. Context – This is a condition identified per review of DCPL’s compliance with the specified requirements using a statistically valid sample. Effect – Failure to adhere to the procurement procedures specified in the Uniform Administrative Requirements may lead to the Federal agency disallowing the procurement and associated costs. Cause – While DCPL adhered to their policies and procedures for private expenditures, the agency did not adhere to federal procurement requirements (2 CFR Section 200.320(c)) listed above to support noncompetitive procurement on the requirements to use sole source. Recommendation – We recommend that management establish the requisite internal control policies and procedures to ensure that all procurements reported under the federal program are in compliance. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – DCPL concurs with the auditor’s findings and recommendations. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.
2024-001 (Significant Deficiency over Compliance): Insufficient Design of Procurement Policy Criteria: Under CFR 200.320, three types of procurement methods are outlined based on the dollar amount and nature of transactions. Condition: The Organization’s existing procurement policy outlines the three methods described under CFR 200.320. However, the policy does not incorporate sufficient monitoring procedures to ensure compliance with the procurement policy. Questioned Costs: There were no questioned costs associated with this finding. Effect: This error potentially resulted in the payment of higher prices for goods and services, violating federal procurement regulations. Recommendation: The Organization should strengthen its policies, training, and monitoring related to procurement to ensure compliance with CFR 200.320.
Criteria:Proper documentation is necessary in purchasing and procurement to ensure accountability, to prevent duplication of payments, and to detect fraud and prevent other errors from occurring.Condition:There were missing invoices and missing copies of check stubs. The fee accountant had to recreate financial records from the bank statements which included copies of canceled checks. In addition, contracts could not be located for maintenance contracts so it could not be determined if the amounts paid were in excess of contract amounts.Effect:Lack of proper documentation could result in undetected fraud, errors, and incomplete financial information.Cause:Lack of oversight by management and the Board.Recommendation:Invoices and other records should be safeguarded to prevent fraud and errors and to insure financial information is complete and accurate.Views of Responsible Officials and Planned Corrective Actions:We agree with the auditors' comments, and the following action will be taken to improve the situation. This situation was created when the previous administration removed all records and were not made available to the auditors after several requests. KMHA has taken the following actions:KMHA's Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The new policy addresses the three types of procurement under CFR 200.320 informal and formal procurement and noncompetitive procurement. Thresholds have been set for Micro purchases and thus simplified procurement under informal practices. Formal methods include Sealed bids and Proposals when sealed bids are not appropriate.All checks are handled in accordance with the new check writing policy and have the necessary documentation to support the purchase and is filed in such a manner to be available for future reviews. This documentation will be made available to the Authority's fee accountant.All procurement actions will be handled in accordance with the new procurement policy and CFR 200.