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
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
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
2023-001 Improve Controls and Documentation Over Procurement Federal Agency: U.S. Department of the Treasury Cluster/Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Fund AL Numbers: 21.027 Award Year: 2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Local municipalities are also required to use the same state procurement policies and procedures for federal funds as for non-federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There was no evidence to support that one disbursement properly followed the procurement process before payments for services were made to the vendor. Cause Weaknesses in the design and operation of controls. 2023-001 Improve Controls and Documentation Over Procurement (Continued) Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that procurements may be awarded to vendors in a manner that is not consistent with federal procurement requirements. Known questioned costs are reported equal to $82,800, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Fund $82,800 Recommendation The Town should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal and state requirements. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
2023-009 Wage Compliance (Repeat Finding 2021/2022-011) CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not comply with the wage rate compliance related to the teacher housing civil construction project or the locker room remodel for expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance 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). Non-federal 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 non-Federal 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). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement for the teacher housing civil construction project, and the locker room remodel project. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract, and that contract includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: SLFRP0128 Grant Year: 2021 Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: June 7, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The Cities procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Policies regarding verification of compliance with suspension and debarment requirements were not found. Questioned Costs: None Context: Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria the population of expenditures requiring testing were immaterial or otherwise excluded from testing requirements. Effect: With the absence of a compliant policy, the City could process transactions that do not follow federal Uniform Guidance procurement standards. Repeat Finding: Yes, 2022-004 Cause: The City was in the process of updating their policy to be in line with the Uniform Guidance procurement standards, but was unable to finalize the policy prior to incurring allowable costs. Recommendation: We recommend the City comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance including the verification that an entity with which the City plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Views of Responsible Officials: Management agrees with the auditors’ recommendations.