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.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.