Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.
United States Department of the Treasury Reference Number: 2023-012 Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal Award Number: None Assigned Type of Finding: Noncompliance and Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Procurement Condition: During our audit of procurement transactions related to the SLFRF, we noted one instance where the Town acquired precast restrooms at a cost of $339,500, for a park project without a competitive bidding process, as required by federal regulations and the Town’s Purchasing Policy. Criteria: Under 2 CFR §200.318-§200.326, non-federal entities must follow documented procurement procedures that reflect applicable state, local, and tribal laws and regulations, provided those procedures conform to federal standards. The Town has adopted procurement policies requiring competitive bidding for purchases of equipment, materials, or professional services, with an estimated total cost exceeding $25,000 for an individual item/service or an overall contract exceeding $50,000. The policy also requires the documentation of vendor selection and justification. Cause: The Town did not consistently enforce its procurement policies due to turnover in key positions during the year. Effect: The Town was not in compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 CFR §200.318-§200.326 and with its own procurement policies. The lack of competitive bidding for purchases, where it is required increases the risk that the Town may not receive the best prices or terms for the goods and services it purchases. Recommendation: We recommend that the Finance Department enhance its processes and oversight surrounding federal and Town procurement requirements. Views of Responsible Town Officials and Planned Corrective Actions: See corrective action plan. Responsible Positions: Town Manager and Director of Finance
Identification as a Repeat Finding: N/A Finding: Blue Mountain Land Trust did not have a written procurement policy that complies with the procurement standards established in 2 CFR sections 200.318 through 200.326 in place during the year. Criteria: Non-Federal entities other than States must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR 200. Condition and context: Blue Mountain Land Trust maintains a practice of soliciting bids for services from at least three contractors, but it has not established a written policy that contemplates all required elements under 2 CFR sections 200.318 through 200.326. Sample size and population: Sampling was not applicable to this finding. Effect: The result of the finding is that Blue Mountain Land Trust is not in compliance with federal procurement standards during the compliance year. Recommendation: Formalize written procurement procedures in compliance with required standards. Question Costs: None Management Response and Corrective Action Plan: See Corrective Action Plan Contact Person: Amanda Martino, Executive Director
Federal agency name: U.S. National Science Foundation & U.S. Department of Commerce Federal program title: Geosciences, Computer and Information Science and Engineering, Office of International Science and Engineering & NOAA – Cooperative Institute AL No.: 47.050, 47.070, 47.079 & 11.432 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026), OISE-1855654 (05/15/2019 – 12/31/2023) & A22NWS4320003 (08/01/2022 – 07/25/2025, 08/01/2022 – 07/25/2025, 04/01/2023 – 03/31/2024, 06/01/2023 – 05/31/2024, 06/01/2023 – 05/31/2026, 06/01/2023 – 05/31/2025, 06/01/2023 – 05/31/2025) Pass Through Entity: University of Alabama MW2023-002 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to non-compliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2023. CUAHSI did not complete the verification of its 2023 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded. Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2022-006. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture Compliance Requirements: Procurement. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.319(d) requires that the non-Federal entity must maintain written procedures for procurement transactions. Condition: We noted that the City did not have written procedures for procurement transactions that include the provisions required by the Procurement Standards 2 CFR § 200.318 through 2 CFR § 200.327 in fiscal year 2023. Cause: The City was not aware of the requirement to have written procedures for procurement transactions. Effect: Failure to have adequate written procedures for procurement transactions could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, other procurement requirements, and Uniform Guidance requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop adequate written policies and procedures for procurement transactions. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.
Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture Compliance Requirements: Procurement. Type of Finding: Material Weakness in Internal Control Over Compliance. Criteria: Internal controls should be in place to provide reasonable assurance that procurement of goods and services are made in compliance with federal regulations and other procurement requirements, as applicable. Condition: The City lacks sufficient controls over procurement to ensure compliance with federal regulations and other procurement requirements, as applicable. Cause: The City did not design and implement controls over compliance with procurement. Effect or Potential Effect: Failure to have adequate internal controls over compliance with procurement could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, and other procurement requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City create and adopt an official written policy for procurement and contracts establishing contract files that document significant procurement history; methods of procurement authorized including selection of contract type, contractor selection or rejection, and the basis of contract price; verification that procurements provide full and open competition; requirements for cost or price analysis, including for contract modifications; obtaining and reacting to suspension and debarment certifications; and other applicable requirements for procurements under federal awards are followed. We also recommend that personnel with adequate knowledge and experience of responsibilities for procurements for federal awards review procurement and contracting decisions for compliance with federal procurement policies. Views of Responsible Officials and Planned Corrective Action: Management concurs with the audit finding. The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where City personnel are not available or qualified to perform.
Finding 2023-003 Federal Program: Coronavirus State and Local Fiscal Recover Funds, AL# 21.027 Type of Finding: Significant deficiency in internal controls over compliance and immaterial non-compliance Compliance Requirement: Procurement Criteria: In accordance with the Uniform Guidance, specifically 2 CFR §200.318, non-federal entities must have documented procurement procedures that conform to the Uniform Guidance 2 CFR §200.318 through §200.326. Condition and Context: The auditee did not have written procurement procedures that conformed to the Uniform Guidance 2 CFR §200.318 through §200.326. However, the auditee did follow the methods of procurement required (per 2 CFR §200.320) for federal procurements made during the audit period. Cause: There were not adequate internal controls over compliance in place to ensure there were written procurement policies that conformed with the Uniform Guidance. Effect: The deficiency in the internal controls over compliance could result in material non-compliance with the procurement compliance requirement of the federal award and the Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend the Organization document procurement policies in a formal written procurement policy that contains all required elements of and conforms to the requirements of the Uniform Guidance. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Significant deficiency in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Title: Social Services Research and Demonstration Program Assistance Listing Number: 93.647 Project Number: 90XP0459-01-00 Award Period: August 31, 2022 – August 30, 2023 Criteria Requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D – Post Federal Award Requirements, Sections 200.318 through 200.326, require that a nonfederal entity establish and follow a written procurement policy that conforms to federal standards. Among other requirements, the written procurement policy must identify formal and informal procurement actions to be taken based on the size of the procurement, covering both goods and services. In this instance, the Organization did not follow their established procurement policy when conducting procurement actions, resulting in noncompliance with both their internal procedures and the federal requirements outlined in 2 CFR 200.318–200.326.. Condition The Organization did not follow their established written procurement policy when conducting procurement transactions. Cause The Organization’s internal controls were insufficient to ensure that the Organization’s written procurement policy provisions were followed. Effect or Potential Effect In our testing, the Organization did not follow the written procurement policy in all 5 samples selected for testing. Questioned Costs $23,064 Recommendation We recommend the Organization implement measures to ensure that its procurement policy is followed for all transactions that fall within the policy. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement.
Reference Number: 2023-05 Finding: Finding Type: Significant Deficiency in Internal Control Over Compliance Title and ALN of Federal Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria or Specific Requirement: I. Procurement – 2 CFR sections 200.318 – 200.326 of the Uniform Guidance require that non-federal entities follow documented procurement procedures that ensure full and open competition. All purchases using federal funds must comply with applicable thresholds, documentation, and approval requirements. Additionally, Franklin County Department of Job and Family Services (the pass-through grantor) requires that subrecipient entities also follow procurement requirements identified. Condition: The Organization did not follow required procurement procedures for subrecipient transactions. Cause: Though a procurement policy exists for the Organization, there was no enforcement of this policy for the federal program. Effect or Potential effect: Failure to follow a formal procurement policy causes the Organization to be out of compliance with Uniform Guidance and/or grant requirements and increases the likelihood of disallowance of costs. Questioned costs: None Identification as a Repeat Finding: N/A – this was not reported as a finding in the prior audit report. Context: The Organization did not follow required procurement procedures under the major program as no competitive bidding or documented justification for sole sourcing was provided. Recommendation: We recommend that the Organization revisit their existing procurement policy and implement a formal process to flag new purchase transactions and ensure the policy is followed. Periodic reviews of procurement activity tied to federal awards should also take place. Views of Responsible Officials: Management agrees with the finding and recommendation.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness) Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Criteria: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. Non-federal entities must also ensure that every purchase order or other contract includes provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Context: During our testing of procurement for the Research and Development Cluster, we noted that the Organization did not provide adequate documentation of price or rate quotations from a qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an additional 4 of the 40 items that met the small purchase threshold and were single sourced, the Organization could not provide adequate documentation of the sole source justification being documented prior to the purchase being made. The sample was not statistically valid. During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN 21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole sourced did not include adequate documentation of sole source justification prior to the purchase. Cause: The Organization did not properly identify certain purchase orders or other contracts as federal award transactions subject to procurement regulations. Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the Organization was not in compliance with Federal procurement requirements.Questioned costs: None Repeat finding: No Recommendation: We recommend management review internal controls over identification of federal contracts for adequacy and ensure internal controls over the procurement process are properly implemented. Views of responsible officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.