Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over its procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. The YWCA did not have Board adopted policies over procurement with federal dollars. The YWCA did not meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. Lastly, the YWCA did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The YWCA’s internal controls over procurement of goods and services were not adequate. Effect The YWCA was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment or procurement. Context During our review of procurement, we noted the following: - The YWCA did not have formal written procedures over procurement. - For one purchase reviewed over $10,000, the YWCA did not go through formal procurement. There was no formal documentation maintained by the YWCA to show prior‐purchase authorization being granted. - For one purchase reviewed over $25,000, the YWCA did not perform a vendor check for suspension and debarment. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The YWCA should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The purchasing department staffing levels did not allow for review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding. The City will update the purchasing policy to include the CFR requirements.
Procurement Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-003
Procurement Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-003
Procurement Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-003
Procurement Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-003
Procurement Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-003