Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: The Organization is required to create a written procurement, suspension and debarment policy that complies with applicable federal requirements as indicated in 2 CFR 200.318 -200.326 and to follow this policy when procuring goods and services.Condition: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids was not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed. Effect: Purchases were made that did not adhere to the Organization’s procurement, suspension and debarment policy. Questioned costs: n/a Context: The Organization did not maintain supporting documentation that management obtained price or rate quotes for purchases above the micro-purchase threshold. In addition, the Health Center did not maintain documentation to support that the vendors were not suspended or debarred, however subsequent testing verified that none of the vendors selected for review were suspended or debarred. Repeat Finding: Yes, 2023-003 Recommendation: The Organization should review and update the procurement and suspension and debarment policies. Additionally, the Organization should provide training to staff on transactions that are covered by the procurement, suspension and debarment policies. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: The Organization is required to create a written procurement, suspension and debarment policy that complies with applicable federal requirements as indicated in 2 CFR 200.318 -200.326 and to follow this policy when procuring goods and services.Condition: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids was not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed. Effect: Purchases were made that did not adhere to the Organization’s procurement, suspension and debarment policy. Questioned costs: n/a Context: The Organization did not maintain supporting documentation that management obtained price or rate quotes for purchases above the micro-purchase threshold. In addition, the Health Center did not maintain documentation to support that the vendors were not suspended or debarred, however subsequent testing verified that none of the vendors selected for review were suspended or debarred. Repeat Finding: Yes, 2023-003 Recommendation: The Organization should review and update the procurement and suspension and debarment policies. Additionally, the Organization should provide training to staff on transactions that are covered by the procurement, suspension and debarment policies. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: The Organization is required to create a written procurement, suspension and debarment policy that complies with applicable federal requirements as indicated in 2 CFR 200.318 -200.326 and to follow this policy when procuring goods and services.Condition: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids was not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed. Effect: Purchases were made that did not adhere to the Organization’s procurement, suspension and debarment policy. Questioned costs: n/a Context: The Organization did not maintain supporting documentation that management obtained price or rate quotes for purchases above the micro-purchase threshold. In addition, the Health Center did not maintain documentation to support that the vendors were not suspended or debarred, however subsequent testing verified that none of the vendors selected for review were suspended or debarred. Repeat Finding: Yes, 2023-003 Recommendation: The Organization should review and update the procurement and suspension and debarment policies. Additionally, the Organization should provide training to staff on transactions that are covered by the procurement, suspension and debarment policies. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: The Organization is required to create a written procurement, suspension and debarment policy that complies with applicable federal requirements as indicated in 2 CFR 200.318 -200.326 and to follow this policy when procuring goods and services.Condition: During the testing performed, it was determined that documentation to support quotes, estimates, or closed bids was not maintained prior to entering into contracts. Additionally, documentation was not maintained to support that the vendors were not suspended or debarred. Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed. Effect: Purchases were made that did not adhere to the Organization’s procurement, suspension and debarment policy. Questioned costs: n/a Context: The Organization did not maintain supporting documentation that management obtained price or rate quotes for purchases above the micro-purchase threshold. In addition, the Health Center did not maintain documentation to support that the vendors were not suspended or debarred, however subsequent testing verified that none of the vendors selected for review were suspended or debarred. Repeat Finding: Yes, 2023-003 Recommendation: The Organization should review and update the procurement and suspension and debarment policies. Additionally, the Organization should provide training to staff on transactions that are covered by the procurement, suspension and debarment policies. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future procurement, suspension and debarment transactions are identified and documentation is maintained to support the evaluation.
Written Procurement Policy This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 84.282, Charter Schools, funded by U.S. Department of Education, passed through the Commonwealth of Massachusetts, Department of Elementary and Secondary Education (DESE). Criteria: The School must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. The School also 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: During our compliance testing, we reviewed the School's procurement policy against Uniform Guidance standards. The policy did not meet all of the considerations that are required through Federal, Uniform Guidance, and state regulations. The School followed their procurement policy during fiscal year 2024, but should update this policy in accordance with these regulations Context: Compliance with the Uniform Guidance. Cause: The School’s existing procurement policy was not updated to include all of the elements required by the Uniform Guidance. Effect: Non-compliance with the Uniform Guidance, potentially resulting in a decrease in Federal funding and allow for purchases that are not completed under the approved procurement standards. Questioned Costs: No questioned costs identified. Was the finding a repeat of a finding in the immediately prior year?: No Recommendation: AAFCPAs recommends that management revise their policy to comply with current standards under the Uniform Guidance. Management’s Response: The current School policy was adopted at opening based on DESE recommended Fiscal Policy and Procedures. Given the analysis of the current policy as compared to the Uniform Guidance policy, the School policy will be updated to ensure compliance going forward. This policy will be reviewed by the Finance Committee and then brought to the full Board for approval no later than January 2025.
2024-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Trust is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Trust is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Trust does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The Trust has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the Trust’s procurement policy are as follows: • Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms • Bonding requirements • Contract provisions • Subrecipient and contractor determinations • Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Trust’s procurement policy appropriately. This would include adding any missing components to the Trust’s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
2024-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Trust is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Trust is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Trust does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The Trust has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the Trust’s procurement policy are as follows: • Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms • Bonding requirements • Contract provisions • Subrecipient and contractor determinations • Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Trust’s procurement policy appropriately. This would include adding any missing components to the Trust’s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
2024-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Trust is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Trust is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Trust does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The Trust has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the Trust’s procurement policy are as follows: • Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms • Bonding requirements • Contract provisions • Subrecipient and contractor determinations • Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Trust’s procurement policy appropriately. This would include adding any missing components to the Trust’s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
2024-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Trust is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Trust is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Trust does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The Trust has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the Trust’s procurement policy are as follows: • Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms • Bonding requirements • Contract provisions • Subrecipient and contractor determinations • Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Trust’s procurement policy appropriately. This would include adding any missing components to the Trust’s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
Finding Type: Significant deficiency in internal controls over major programs and noncompliance with laws and regulations. Program Impacted: Education Stabilization Fund; ARP ESSER III (84.425U) Condition: All required payrolls were not submitted by contractors or subcontractors for work performed by laborers on projects funded, in part, by the Education Stabilization Fund grant. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000, financed by federal assistance funds, must be paid wages no less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (40 USC 3141-3144, 3146, and 3147). The reporting for this includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which work is performed, a copy of the payroll and statement of compliance (certified payrolls) (2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Cause: The District did not maintain effective internal controls over the review of certified payrolls to ensure that prevailing wages were paid to mechanics and other laborers working on the contract. Effect: The District is unable to verify compliance with prevailing wage rate requirements for projects funded under the grant. Context: We evaluated 3 vendors as part of our review of wage rate requirements and noted the following: *For 1 of the 3 vendors reviewed, certified payrolls were not submitted to the District. Questioned Costs: $0, program funding associated with construction was used for supplies and materials only. Such costs were budgeted for, and approved by, the grantor agency. Recommendation: The District should implement internal controls that include review of certified payrolls for all construction projects funded by federal grant dollars. District’s Response: The District agrees with the finding and will develop internal control procedures necessary to correct the condition.
U.S. Department of Education passed through Utah State Board of Education 2024-001 Special Tests and Provisions – Wage Rate Requirements Education Stabilization Fund: COVID-19 American Rescue Plan – Elementary and Secondary School Emergency Relief (84.425U) Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor of subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215 Appendix A, Contract Provisions; 2 CFR Part 176 Subpart C; and 2 CFR section 200.326). Context and Condition: We reviewed the District’s construction contracts that were financed by the Education Stabilization Fund during the year ended June 30, 2024 and performed testing over internal controls and compliance as related to the Wage Rate Requirements as outlined in the criteria above. Cause: The District did not have processes or controls established to ensure certified payrolls for each week in which contract work was performed were obtained from subcontractors for one of two construction contracts financed by the Education Stabilization Fund until after the construction contract was completed. Effect: A potential failure to pay laborers and mechanics employed by contractors or subcontractors prevailing wage rates as required by the Wage Rate Requirements exists. Questioned Costs: No costs were questionable Repeat finding: No Statistically valid: Yes Recommendation: We recommend management of the District review processes related to construction projects subject to the Wage Rate Requirements and establish appropriate internal controls to ensure all wage rate requirements are met. Views of responsible officials: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to, when applicable.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: We noted that the District does have policies and procedures in place for compliance with procurement requirements. However, we noted one out of eight vendors did not have an updated sole source justification form on file covering the current fiscal year. Questioned costs: None Context: One vendor, out of a sample of eight, did not have an updated sole source justification form covering the current fiscal year. Cause: The District’s approval of sole source justification forms is typically valid for the life of the business with the vendor, but this one instance had an expiration date on the approval of the vendor as a sole source that ended prior to the current fiscal year. An updated sole source justification from was not completed after the expiration of the previous approval. Effect: Failure to document the procurement process exposes the District to the risk that the District’s procurement policy was not followed before the contracts were awarded. Repeat Finding: NoRecommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: We noted that the District does have policies and procedures in place for compliance with procurement requirements. However, we noted one out of eight vendors did not have an updated sole source justification form on file covering the current fiscal year. Questioned costs: None Context: One vendor, out of a sample of eight, did not have an updated sole source justification form covering the current fiscal year. Cause: The District’s approval of sole source justification forms is typically valid for the life of the business with the vendor, but this one instance had an expiration date on the approval of the vendor as a sole source that ended prior to the current fiscal year. An updated sole source justification from was not completed after the expiration of the previous approval. Effect: Failure to document the procurement process exposes the District to the risk that the District’s procurement policy was not followed before the contracts were awarded. Repeat Finding: NoRecommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: We noted that the District does have policies and procedures in place for compliance with procurement requirements. However, we noted one out of eight vendors did not have an updated sole source justification form on file covering the current fiscal year. Questioned costs: None Context: One vendor, out of a sample of eight, did not have an updated sole source justification form covering the current fiscal year. Cause: The District’s approval of sole source justification forms is typically valid for the life of the business with the vendor, but this one instance had an expiration date on the approval of the vendor as a sole source that ended prior to the current fiscal year. An updated sole source justification from was not completed after the expiration of the previous approval. Effect: Failure to document the procurement process exposes the District to the risk that the District’s procurement policy was not followed before the contracts were awarded. Repeat Finding: NoRecommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: We noted that the District does have policies and procedures in place for compliance with procurement requirements. However, we noted one out of eight vendors did not have an updated sole source justification form on file covering the current fiscal year. Questioned costs: None Context: One vendor, out of a sample of eight, did not have an updated sole source justification form covering the current fiscal year. Cause: The District’s approval of sole source justification forms is typically valid for the life of the business with the vendor, but this one instance had an expiration date on the approval of the vendor as a sole source that ended prior to the current fiscal year. An updated sole source justification from was not completed after the expiration of the previous approval. Effect: Failure to document the procurement process exposes the District to the risk that the District’s procurement policy was not followed before the contracts were awarded. Repeat Finding: NoRecommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: We noted that the District does have policies and procedures in place for compliance with procurement requirements. However, we noted one out of eight vendors did not have an updated sole source justification form on file covering the current fiscal year. Questioned costs: None Context: One vendor, out of a sample of eight, did not have an updated sole source justification form covering the current fiscal year. Cause: The District’s approval of sole source justification forms is typically valid for the life of the business with the vendor, but this one instance had an expiration date on the approval of the vendor as a sole source that ended prior to the current fiscal year. An updated sole source justification from was not completed after the expiration of the previous approval. Effect: Failure to document the procurement process exposes the District to the risk that the District’s procurement policy was not followed before the contracts were awarded. Repeat Finding: NoRecommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-003: Material Weakness – Controls and Compliance over Special Tests and Provisions Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: Certified payrolls were not obtained or reviewed by the District. Program expenditures for fiscal 2024 included one construction contract. Cause: The District was not aware of this specific requirement. Effect: Federal funds may be paid to a contractor or subcontractor that pays wages less than the prevailing wage rates. Questioned Costs: None noted. Recommendation: We recommend that the District implement a process to obtain certified payrolls when using federal funds on construction contracts. Once the certified payrolls are obtained, the District should review them as outlined by the applicable federal regulations and retain documentation of their conclusion. Views of responsible officials: The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District has since received and reviewed the certified payrolls and determined the contractor is in compliance.
Finding 2024-003: Material Weakness – Controls and Compliance over Special Tests and Provisions Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: Certified payrolls were not obtained or reviewed by the District. Program expenditures for fiscal 2024 included one construction contract. Cause: The District was not aware of this specific requirement. Effect: Federal funds may be paid to a contractor or subcontractor that pays wages less than the prevailing wage rates. Questioned Costs: None noted. Recommendation: We recommend that the District implement a process to obtain certified payrolls when using federal funds on construction contracts. Once the certified payrolls are obtained, the District should review them as outlined by the applicable federal regulations and retain documentation of their conclusion. Views of responsible officials: The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District has since received and reviewed the certified payrolls and determined the contractor is in compliance.
U.S. Department of Education passed through State of Utah Board of Education 2024-001 Procurement and Suspension and Debarment Program Name of Federal Program (Assistance Listing Number): Substance Abuse and Mental Health Services Projects of Regional and National Significance (93.243) Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). The District’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The District also has procedures to identify procurement transactions requiring competitive bids or proposals. Context and Condition: We selected six contracts to test for compliance with procurement standards. Records for four contracts lacked documentation sufficient to detail procurement history. Cause: The District did not follow its documentation policy for obtaining contracts or bids. Effect: A potential failure to conduct procurement transactions in a manner providing full and open competition exists. Questioned Costs: No costs were questionable Recommendation: We recommend the District ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Views of responsible officials: The District will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified.
Finding 2024-003: Material Weakness - Internal Control and Compliance Over Special Tests and Provisions Program: COVID-19: Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146 and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: The District did not enter into a contract with the primary contractor for the HVAC construction project paid for with federal assistance funds, nor did the District verify that prevailing wage rate requirements were included in subcontracts. Additionally, the District does not have controls in place to track weekly certified payrolls. Cause: The District did not have controls in place to ensure federal requirements were met in the process for selecting contractors and monitoring subcontractors. The District also does not have a process in place to track the weekly certified payrolls. Effect: Federal Funds may be paid to a contractor that does not follow prevailing wage laws. Questioned Costs: Not determinable. Recommendation: We recommend the District implement a system for procurement procedures to ensure contacts are obtained and include the required prevailing wage rate requirements. This should also include monitoring all subcontractors to ensure they meet these requirements. We also recommend the District implement a system to track weekly certified payrolls to ensure all payrolls are received. Views of Responsible Officials: The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.
Finding 2024-003: Material Weakness - Internal Control and Compliance Over Special Tests and Provisions Program: COVID-19: Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146 and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: The District did not enter into a contract with the primary contractor for the HVAC construction project paid for with federal assistance funds, nor did the District verify that prevailing wage rate requirements were included in subcontracts. Additionally, the District does not have controls in place to track weekly certified payrolls. Cause: The District did not have controls in place to ensure federal requirements were met in the process for selecting contractors and monitoring subcontractors. The District also does not have a process in place to track the weekly certified payrolls. Effect: Federal Funds may be paid to a contractor that does not follow prevailing wage laws. Questioned Costs: Not determinable. Recommendation: We recommend the District implement a system for procurement procedures to ensure contacts are obtained and include the required prevailing wage rate requirements. This should also include monitoring all subcontractors to ensure they meet these requirements. We also recommend the District implement a system to track weekly certified payrolls to ensure all payrolls are received. Views of Responsible Officials: The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance 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. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. 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 compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement 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 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: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of 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 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.