Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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.
Department of Labor, YouthBuild Federal Financial Assistance Listing Number # 17.274, 2020-2023 Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected. For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected. Repeat Finding from Prior Years: Yes Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections. Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild Federal Financial Assistance Listing Number # 17.274, 2020-2023 Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected. For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected. Repeat Finding from Prior Years: Yes Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections. Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild Federal Financial Assistance Listing Number # 17.274, 2020-2023 Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected. For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected. Repeat Finding from Prior Years: Yes Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections. Views of Responsible Officials: Management is in agreement with this finding.
U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Procurement Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. The Organization is required to create a written procurement, suspension, and debarment policy that complies with applicable federal requirements and to follow this policy when procuring goods and services. The Organization is also required to retain documentation supporting performance of a price analysis and open competition. Condition: The Organization’s procurement policy does not contain all provisions required by Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a price analysis over the transactions tested. Cause: The Organization has limited staffing and did not have proper controls in place relating to review of the procurement policy. Effect: The Organization did not ensure that the procurement policy was complete and accurate. Questioned Costs: None reported. Context: A nonstatistical sample of 4 out of 9 procurement transactions were selected for testing, which accounted for $175,792 of $370,234 qualified expenditures.Repeat Finding from Prior Years: No Recommendation: We recommend the Organization follow control processes implemented which includes updating the procurement policy and documenting the performance of required procurement procedures. Views of Responsible Officials: Management agrees with the finding.
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: USDA School Breakfast Program and National School Lunch Program FAL Number: 10.553 and 10.555 Passthrough: New Mexico Public Education Department Award Year: 2022 Criteria: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, sub awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. §200.317 Procurements by states. When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. The state will comply with §200.322 Procurement of recovered materials and ensure that every purchase order or other contract includes any clauses required by section §200.326 Contract provisions. All other non-Federal entities, including sub recipients of a state, will follow §200.318 General procurement standards through 200.326 Contract provisions. §200.318 General procurement standards. (a) The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” https://www.sam.gov/portal/public/SAM/ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: During our testing of single audit disbursements, we identified five vendors which would meet the requirement of verifying that the vendor was not suspended or debarred or otherwise excluded from receiving the contract which was funded through Federal dollars. The vendor received single payments in excess of $25,000 from the District from Federal grant sources. The vendors are not currently suspended or debarred from receiving Federal contracts; however, the District did not have proper internal controls in place to verify this prior to the purchase. Questioned Costs: None Cause: District personnel did not verify that vendors which meet the $25,000 thresholds are not suspended, debarred, or otherwise excluded from participating in contracts funded through Federal awards due to a misunderstanding of staff personnel regarding this requirement. Effect: The District is not in compliance with Federal regulations related to the grant and could put funding in jeopardy or require the District to reimburse the program for improper grant distributions.Auditor’s Recommendation: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors are not suspended or debarred. The District may have the vendor provide an annual certification that it is not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive but also effective in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for finding: The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. • Timeline for completion of corrective action plan: July 1, 2023 • Employee position(s) responsible for meeting the timeline: Grants Specialists, CPO, Finance Specialist, Purchasing Specialist, Federal Grants Coordinator, Federal Grants Specialist
Section III. Findings and Questioned Costs for Federal Awards 2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: This is a repeat audit finding from the prior year audit and was reported as finding 2021-002. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. View of Responsible Officials: The Law School agrees with the finding and have adopted an appropriate procurement policy as of June 15, 2022. Awards, including sole source awards will be adequately documented.
Criteria: Federal regulations 2 CFR 200.318 states that the Airport must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. In addition, 2 CFR 200.303 states, the Airport, as a recipient of federal funds, must establish and maintain effective internal controls over its federal awards that provides reasonable assurance that the Airport is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted the Airport had not adopted a procurement policy in compliance with federal regulations as noted in the previous audit. Cause: The Airport has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a contract that may not be in compliance with federal standards. Questioned Costs: None noted. Repeat Finding: Yes Recommendation: We recommend that the Airport adopt and document a procurement policy that is in compliance with federal regulations. Response: Please see final page of this report for management?s response as found on the Airport?s letterhead.
Criteria: Federal regulations 2 CFR 200.318 states that the Airport must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. In addition, 2 CFR 200.303 states, the Airport, as a recipient of federal funds, must establish and maintain effective internal controls over its federal awards that provides reasonable assurance that the Airport is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted the Airport had not adopted a procurement policy in compliance with federal regulations as noted in the previous audit. Cause: The Airport has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a contract that may not be in compliance with federal standards. Questioned Costs: None noted. Repeat Finding: Yes Recommendation: We recommend that the Airport adopt and document a procurement policy that is in compliance with federal regulations. Response: Please see final page of this report for management?s response as found on the Airport?s letterhead.
Criteria: Federal regulations 2 CFR 200.318 states that the Airport must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. In addition, 2 CFR 200.303 states, the Airport, as a recipient of federal funds, must establish and maintain effective internal controls over its federal awards that provides reasonable assurance that the Airport is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted the Airport had not adopted a procurement policy in compliance with federal regulations as noted in the previous audit. Cause: The Airport has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a contract that may not be in compliance with federal standards. Questioned Costs: None noted. Repeat Finding: Yes Recommendation: We recommend that the Airport adopt and document a procurement policy that is in compliance with federal regulations. Response: Please see final page of this report for management?s response as found on the Airport?s letterhead.
Criteria: Federal regulations 2 CFR 200.318 states that the Airport must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. In addition, 2 CFR 200.303 states, the Airport, as a recipient of federal funds, must establish and maintain effective internal controls over its federal awards that provides reasonable assurance that the Airport is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted the Airport had not adopted a procurement policy in compliance with federal regulations as noted in the previous audit. Cause: The Airport has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a contract that may not be in compliance with federal standards. Questioned Costs: None noted. Repeat Finding: Yes Recommendation: We recommend that the Airport adopt and document a procurement policy that is in compliance with federal regulations. Response: Please see final page of this report for management?s response as found on the Airport?s letterhead.
Criteria: Federal regulations 2 CFR 200.318 states that the Airport must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. In addition, 2 CFR 200.303 states, the Airport, as a recipient of federal funds, must establish and maintain effective internal controls over its federal awards that provides reasonable assurance that the Airport is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted the Airport had not adopted a procurement policy in compliance with federal regulations as noted in the previous audit. Cause: The Airport has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a contract that may not be in compliance with federal standards. Questioned Costs: None noted. Repeat Finding: Yes Recommendation: We recommend that the Airport adopt and document a procurement policy that is in compliance with federal regulations. Response: Please see final page of this report for management?s response as found on the Airport?s letterhead.
2022-001 PROCUREMENT Federal Assistance Listing Number: Higher Education Emergency Relief Fund (HEERF) 84.425F Criteria A non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The College must use its 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. Observation/Condition/Context The College did not follow its procurement policy in one identified instance out of six tested. It was noted that the College did not solicit competitive price quotations for a purchase exceeding policy thresholds under the HEERF program. Questioned Cost There were no questioned costs associated with this finding. Cause/Effect Following the established procurement policy allows for cost comparison and the ability to evaluate whether a vendor is reputable and if the contract has all the required provisions. By not following the policy, the College opens itself up to higher costs. Recommendation We recommend that the College implement a review process to identify potential instances of noncompliance with the College?s procurement policy.
Finding No. 2022-001 Procurement Federal Agency: Federal Communications Commission Federal Program Name: COVID 19 ? Emergency Connectivity Fund Program Assistance Listing Number: 32.009 Award Period: July 1, 2021 through August 29, 2023 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria The City must comply with their purchasing policy, which encompasses the procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City?s procurement for two vendors did not comply with Uniform Guidance. Questioned Costs $1,472,280 Context The City is required to utilize a sealed bidding process for expenditures in excess of the $250,000 threshold per Uniform Guidance. As a result of our testing, we noted two out of two vendors selected for testing with expenditures in excess of the threshold which did not utilize the sealed bidding process. The sample was a statistically valid sample. Effect The City made purchases that did not follow federal Uniform Guidance procurement standards. Cause The City had very limited time to apply for this grant funding. They obtained competitive quotations as the sealed bidding process would not have been feasible given the time needed to go through the process. However, a bid waiver was not obtained, although it could have been within the necessary timeframe.
Finding No. 2022-001 Procurement Federal Agency: Federal Communications Commission Federal Program Name: COVID 19 ? Emergency Connectivity Fund Program Assistance Listing Number: 32.009 Award Period: July 1, 2021 through August 29, 2023 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria The City must comply with their purchasing policy, which encompasses the procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City?s procurement for two vendors did not comply with Uniform Guidance. Questioned Costs $1,472,280 Context The City is required to utilize a sealed bidding process for expenditures in excess of the $250,000 threshold per Uniform Guidance. As a result of our testing, we noted two out of two vendors selected for testing with expenditures in excess of the threshold which did not utilize the sealed bidding process. The sample was a statistically valid sample. Effect The City made purchases that did not follow federal Uniform Guidance procurement standards. Cause The City had very limited time to apply for this grant funding. They obtained competitive quotations as the sealed bidding process would not have been feasible given the time needed to go through the process. However, a bid waiver was not obtained, although it could have been within the necessary timeframe.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
2022-002 Procurement and Suspension and Debarment Federal Agency: United States Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number: 12060-OPM20600-29669 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: Material Noncompliance Material Weakness in Internal Control over Compliance Criteria or specific requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement policy does not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In addition, the Town did not properly go out to a sealed bid for an item procured by the grant in accordance with their existing policy. The Town did receive comparable pricing for the item tested, however documentation was not retained to indicate approval for waiving sealed bid requirements. Furthermore, there were no controls in place to review for suspension and debarment on related procurement activities. Questioned Costs: $215,000 Context: There was one selection tested for procurement and three selections tested for suspension and debarment . Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to all federal procurement requirements. Repeat Finding: No. Recommendations: We recommend that the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. 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 its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. 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 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-006 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425C220015, S425D220045, and S425C220045 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: Per 2 CFR Part 176, Subpart C and 2 CFR section 200.326, the District shall include in their construction contracts subject to the wage requirements a special provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payments). Condition: During special provisions testing, it was noted that for 3 of 3 contractors tested that the required wage rate requirements were not included and the District did not require the contractors to submit certified payments. Questioned Costs: Not determinable. Context: 3 of 3 contracts tested did not follow proper wage requirements. Cause: Oversight. Effect: Lack of proper controls and noncompliance with wage rate requirements could result in the District doing business with contractors that are not paying laborer or mechanics prevailing wage rates. Repeat Finding: No. Recommendation: We recommend that the District consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. If it is determined that wage rate requirements apply, the District should ensure the required provision is included in the applicable contracts and then the District also needs to require the applicable contractors to submit certified payrolls during the time of the projects. Views of Responsible Official: There is no disagreement with the finding.