Finding 2024-004 – PROCUREMENT (repeat finding) Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Grant Name: Access to Behavioral Crisis Services Grantor Number: FG-22-099 Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, formal procurement methods 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 follow the formal procurement methods outlined in 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: This condition was caused by an insufficient internal control process for procurement including 1) requirement/review and approval of formal bid, and 2) review for suspension and debarment. Effect: The CMHSP purchased several items pursuant to a contract that did not go through a formal bid process or have evidence of review for suspension and debarment. Questioned Cost: $340,014 Context: One contract was paid from grant funds. The questioned cost shown above reflects the amount paid from grant funds for the year pursuant to this contract which did not go through a formal bid process or have evidence of review for suspension and debarment. 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 their internal controls and make necessary changes to ensure that procurements adhere to the requirements of 2 CFR 200. Management’s Resp: We are in agreement with this finding.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
2024-002 Procurement Space Operations Assistance Listing Number: 43.007 Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2024 Funding, Repeat Finding Criteria: 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete when it makes sense regardless of the threshold and can be achieved by obtaining three quotes, i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition. CASIS may solicit a proposal from only one source in circumstances where one or more of the following conditions apply (FAR Subpart 6.3): (i) The item or service is available only from a single source. supplies or services to be procured immediately. (iii) NASA specifically authorizes the use of noncompetitive proposals (directed source). (iv) After consultation with a number of sources, competition is determined inadequate. (v) The vendor is listed as a sole source provider under the Cooperative Agreement. Condition: Sole source determination was not documented for two vendors. Cause: For two legal expenses tested in the sample, no documentation of this being a sole source purchase prior to expending the funds. Effect: If CASIS cannot demonstrate that procurement of services were properly sole sourced, this may result in questioned costs and funds being returned to NASA. Questioned Costs: Known questioned costs of $41,762 and likely questioned costs of $90,024. Perspective: There were 2 out of 60 expenses selected for which the control failed. Recommendation: Non-competitive procurement should be documented and approved prior to incurring expenses. Management Response: CASIS acknowledges the error documenting these procurements. The two legal service vendors had been discussed internally and the selections rationalized based on the specialty of the professional services required for leasing and employment matters. Unfortunately, the documentation was not completed and stored as required by our internal policies. We consider these costs to be both necessary and reasonable, as we were negotiating a new office space lease and the rates were consistent with other legal service providers that CASIS has procured. CASIS plans on reinforcing the procurement documentation requirements with our personnel through additional training and reminding that engagement letters need to go through our document review software.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Reference Number: 2024-002 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance AL Number(s) and Title(s): 10.553 and 10.555 – Child Nutrition Cluster Federal Awarding Agency: U.S. Department of Agriculture Federal Award Number: 255AL322N1199 Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $62,778.22 Child Nutrition Cluster funds were used to pay $62,778.22 for services and supplies without obtaining required quotes. The U. S. Code of Federal Regulations Title 2, Part 200.320(a), of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that the recipient or subrecipient is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. The Board’s documented procurement procedures state that the procurement transactions for federal programs and child nutrition programs that are not subject to the state procurement laws but exceed the aggregate amount of the federal micro-purchase threshold of $10,000 will be obtained by utilizing price or rate quotes from two or more qualified sources. Septic tank services, equipment maintenance/repair services, and kitchen supplies in the amount of $62,778.22 were paid from Child Nutrition Cluster funds. The Board failed to obtain price or rate quotes from an adequate number of qualified sources during the audit period. As a result, the Board failed to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a). Recommendation: The Board should comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.320 by following its documented procurement procedures. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Reference Number: 2024-002 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance AL Number(s) and Title(s): 10.553 and 10.555 – Child Nutrition Cluster Federal Awarding Agency: U.S. Department of Agriculture Federal Award Number: 255AL322N1199 Pass-through Entity: Alabama Department of Education Pass-through Award Number: None Questioned Costs: $62,778.22 Child Nutrition Cluster funds were used to pay $62,778.22 for services and supplies without obtaining required quotes. The U. S. Code of Federal Regulations Title 2, Part 200.320(a), of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that the recipient or subrecipient is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. The Board’s documented procurement procedures state that the procurement transactions for federal programs and child nutrition programs that are not subject to the state procurement laws but exceed the aggregate amount of the federal micro-purchase threshold of $10,000 will be obtained by utilizing price or rate quotes from two or more qualified sources. Septic tank services, equipment maintenance/repair services, and kitchen supplies in the amount of $62,778.22 were paid from Child Nutrition Cluster funds. The Board failed to obtain price or rate quotes from an adequate number of qualified sources during the audit period. As a result, the Board failed to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a). Recommendation: The Board should comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.320 by following its documented procurement procedures. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
2024-001 Finding Type Material Weakness, Noncompliance Federal Program Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting a vendor whose expenditures exceeded the micro-purchase threshold. Cause The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $182,483 that were not in compliance with procurement standards. Questioned Costs $182,483 Identification of a Repeat Finding This is not a repeat finding from the prior year’s audit. Recommendation We recommend the Organization has an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Congressional Appropriations Program, Public Law '118.420 Assistance Listing Number: 21.U01 NeighborWorks System Program FY 2024 Appropriation Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Corporation should have internal controls designed to ensure compliance with those provisions. In addition, 2 CFR Part 200.320(c) states that there are specific circumstances in which the recipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: (1) The aggregate amount of the procurement transaction does not exceed the micro-purchase; (2) The procurement transaction can only be fulfilled by a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; (4) The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or (5) After soliciting several sources, competition is determined inadequate. Condition: During our testing, we noted two procurement samples were procured by way of a noncompetitive proposal process through a solicitation from only one source that did not meet the circumstances of 2 CFR Part 200.320(c). The sole source justifications that were documented in the procurement files for these two samples were not in compliance with the Uniform Guidance. Questioned costs: Not determinable Context: We selected samples from three populations of vendors who had federal expenses in fiscal year 2024 based on when the procurements were completed. The two exceptions were from the population of procurements completed prior to March 2023. These procurements were completed in February 2020 and July 2022, respectively. Total federal expenditures related to these procurements were $194,571 during fiscal year 2024 and the total award amounts were $1,035,000. We did not identify exceptions in our testing of procurements completed March 2023 or after. Cause: Prior to fiscal year 2024, at the time these procurements were performed, the Corporation’s procurement policy allowed sole source justifications that were not compliant with the Uniform Guidance. Effect: The Corporation incurred federal expenses during fiscal year 2024 under procurements that did not comply with the requirements of the Uniform Guidance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend the Corporation ensure controls are in place so that expenses charged to federal programs are in compliance with the procurement requirements of the Uniform Guidance. As part of this, the Corporation should consider identifying active contracts that were improperly procured and determine actions to correct the noncompliance. Views of responsible officials: There is no disagreement with the audit finding.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: Various Criteria 2 CFR 200.320(a) establishes informal procurement methods, including micro-purchases in 2 CFR 200.320 (a)(1), for small purchases in order to expedite the completion of transaction, minimize administrative burdens, and reduce costs. 2 CFR 200.320(a)(1)(v) allows recipients to increase the micropurchase thresholds to higher than $50,000 with approval of the entity’s cognizant agency for indirect costs. The request must include a self-certification of the following requirements from 2 CFR 200.320 (a)(1)(iv): (A) Qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) Annual internal institutional risk assessment to identify, mitigate, and manage financials risks; and, (C) For public institutions, a higher threshold is consistent with State law. The increased threshold is valid until any factor that was relied on in the establishment and rationale of the threshold changes. Condition In October 2022, the University received approval from the U.S. Department of Health and Human Services (DHHS) to raise its micro-purchase threshold to $75,000 having self-certified that it met the criteria of 2 CFR 200.320 (a)(1)(iv). In January 2024, in connection with the issuance of the September 30, 2023 financial statements, UAH reported a material weakness in internal control over financial reporting. This resulted in the University no longer being a low-risk auditee for the September 30, 2024 Uniform Guidance audit and thus no longer meeting the criteria that was relied upon by DHHS when providing the approval to raise the University’s micro-purchase threshold to $75,000. As a result, the increased threshold was no longer valid, and the University did not lower its micro-purchase threshold to $10,000 in January 2024 when the material weakness was identified. The University of Alabama in Huntsville Schedule of Findings and Questioned Costs Year Ended September 30, 2024 17 Cause Management’s process did not allow for communication of the change in auditee status to the parties impacted by the change. Effect Certain purchases made under Federal grants and contracts between $10,000 and $74,999 from February 1, 2024 through September 30, 2024 lacked sufficient documentation to support the justification and rationale for the selection of the specific vendor (e.g., there was no sole source form or other documentation where only one vendor was used). Questioned Costs None. Recommendation We recommend that the University design and implement a control whereby the financial reporting department communicates the results of the annual financial statement audit to those responsible for the Uniform Guidance compliance audit, including Procurement Services, as soon as the financial statement audit is complete, so that the auditee status can be evaluated and any changes to Procurement Services policies and procedures can be made and applied in a timely manner. Management’s View and Corrective Action Plan Management’s response is reported in “Management’s View and Corrective Action Plan” on the following page.
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.