2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
2022-001 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 ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow its procedures as they relate to the contracts under the procurements applicable to the Town's major program. Cause: The Town did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No. Recommendation: We recommend that the Town reviews its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness 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 did not have a written policy on procurement that satisfied 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 documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. 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 addresses 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. Views of Responsible Officials ? There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness 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 did not have a written policy on procurement that satisfied 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 documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. 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 addresses 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. Views of Responsible Officials ? There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness 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 did not have a written policy on procurement that satisfied 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 documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. 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 addresses 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. Views of Responsible Officials ? There is no disagreement with the audit finding.
Criteria In accordance with 2 CFR section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Conditions For the year ended June 30, 2022, the Town of Yoder, Wyoming did not have a written procurement policy implemented with all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause The Town of Yoder, Wyoming has a small staff with the lack of understanding of the requirements. Effect or Potential Effect Lack of a formal, documented procurement policy may result in noncompliance with federal and state statutes, regulations, or other laws. Questioned Costs There were no questioned costs identified, as the parties involved in these covered transactions were neither suspended nor debarred. Context This was identified through inquiry of management and review of the Town of Yoder, Wyoming?s policies. Recommendations We recommend that the Town of Yoder, Wyoming implement a formal, written policy with the requirements of 2 CFR section 200.318 through 200.326 of the Uniform Guidance.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Program Assistance Listing Number: 14.231 Pass-Through Agencies: State of Connecticut Department of Housing and City of New Haven, Connecticut Pass-Through Numbers: CAPO 60210084, CAPO 40220089, and CAPO 40210089 Award Period: Various dates ending between May 18, 2022 and September 30, 2022 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The Organization?s procurement policy does not include the essential restrictive terminology requirements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted Context: Although the Organization did not have a policy in place with the restrictive terminology requirements as detailed in Uniform Guidance, the Organization did follow the federal procedures as it relates to the contracts under the procurements applicable to the Organization?s major program. Cause: The Organization was unaware of the restrictive terminology requirements required as part of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: This was not a repeat finding. Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: There is no disagreement with the audit finding.
2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
Statement of Condition: None of the current year ESSER construction contracts included the Wage Rate Requirement (Davis-Bacon Act) notification to the contractors, nor was weekly certified payroll received from contractors and their subcontractors. Criteria: 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 require the following for construction contracts in excess of $2,000 financed by federal assistance funds. 1) Construction contracts shall include a provision that contractors or subcontractors comply with the provisions of the Wage Rate Requirements (Davis-Bacon Act). 2) These provisions include a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of certified payroll. Cause of Condition: District employees involved in the construction contract writing process were unaware of this requirement. Effect of condition: All construction contract financed by the ESSER program originated during 2022 did not include the Wage Rate Requirements provision. Context: All four applicable contract were reviewed. This finding was present in all four contracts. Recommendation: To ensure that all construction contracts in excess of $2,000 that are financed by federal assistance funds include the required Wage Rate Requirements provision, additional training in ESSER requirements should be provided for employees involved in the construction contract writing process. Further, a review process should be put in place for all such contracts written in order to ensure that they comply with all the requirements within the Compliance Supplement.
Statement of Condition: None of the current year ESSER construction contracts included the Wage Rate Requirement (Davis-Bacon Act) notification to the contractors, nor was weekly certified payroll received from contractors and their subcontractors. Criteria: 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 require the following for construction contracts in excess of $2,000 financed by federal assistance funds. 1) Construction contracts shall include a provision that contractors or subcontractors comply with the provisions of the Wage Rate Requirements (Davis-Bacon Act). 2) These provisions include a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of certified payroll. Cause of Condition: District employees involved in the construction contract writing process were unaware of this requirement. Effect of condition: All construction contract financed by the ESSER program originated during 2022 did not include the Wage Rate Requirements provision. Context: All four applicable contract were reviewed. This finding was present in all four contracts. Recommendation: To ensure that all construction contracts in excess of $2,000 that are financed by federal assistance funds include the required Wage Rate Requirements provision, additional training in ESSER requirements should be provided for employees involved in the construction contract writing process. Further, a review process should be put in place for all such contracts written in order to ensure that they comply with all the requirements within the Compliance Supplement.
Statement of Condition: None of the current year ESSER construction contracts included the Wage Rate Requirement (Davis-Bacon Act) notification to the contractors, nor was weekly certified payroll received from contractors and their subcontractors. Criteria: 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 require the following for construction contracts in excess of $2,000 financed by federal assistance funds. 1) Construction contracts shall include a provision that contractors or subcontractors comply with the provisions of the Wage Rate Requirements (Davis-Bacon Act). 2) These provisions include a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of certified payroll. Cause of Condition: District employees involved in the construction contract writing process were unaware of this requirement. Effect of condition: All construction contract financed by the ESSER program originated during 2022 did not include the Wage Rate Requirements provision. Context: All four applicable contract were reviewed. This finding was present in all four contracts. Recommendation: To ensure that all construction contracts in excess of $2,000 that are financed by federal assistance funds include the required Wage Rate Requirements provision, additional training in ESSER requirements should be provided for employees involved in the construction contract writing process. Further, a review process should be put in place for all such contracts written in order to ensure that they comply with all the requirements within the Compliance Supplement.
Statement of Condition: None of the current year ESSER construction contracts included the Wage Rate Requirement (Davis-Bacon Act) notification to the contractors, nor was weekly certified payroll received from contractors and their subcontractors. Criteria: 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 require the following for construction contracts in excess of $2,000 financed by federal assistance funds. 1) Construction contracts shall include a provision that contractors or subcontractors comply with the provisions of the Wage Rate Requirements (Davis-Bacon Act). 2) These provisions include a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of certified payroll. Cause of Condition: District employees involved in the construction contract writing process were unaware of this requirement. Effect of condition: All construction contract financed by the ESSER program originated during 2022 did not include the Wage Rate Requirements provision. Context: All four applicable contract were reviewed. This finding was present in all four contracts. Recommendation: To ensure that all construction contracts in excess of $2,000 that are financed by federal assistance funds include the required Wage Rate Requirements provision, additional training in ESSER requirements should be provided for employees involved in the construction contract writing process. Further, a review process should be put in place for all such contracts written in order to ensure that they comply with all the requirements within the Compliance Supplement.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.
US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Institutional Aid Portion Assistance Listing #: 84.425F Finding: 2022 – 001 MATERIAL NONCOMPLIANCE / SIGNIFICANT DEFICIENCY Procurement Condition: The College does not have documented procurement procedures. Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures. Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.” Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures. Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200. Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200. Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.
2022-004 - Procurement, Suspension & Debarment Federal Program Information: ALN - 10.760 - Water and Waste Disposal Systems for Rural Communities Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317-200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population. Repeat Finding: This is a repeat finding of 2021-004. Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding, and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
2022-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Town is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Town 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 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 requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Cause: The Town had not adopted a procurement policy that covered 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 were not addressed in the policy followed by the Town during the fiscal year. Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Town’s procurement policy appropriately. This would include adding any missing components to the Town’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.
Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state and local laws and regulations, provided that the procurement standards conform to the applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Organization has a procurement policy in place; however, the Organization is not consistently following the procurement policy. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with procurement requirements. Consequently, for four (4) of four (4) contracts tested, the procurement policy was not followed and no documentation to reflect compliance with Uniform Guidance requirements related to procurement could be provided. Cause: The Organization did not have proper controls in place to monitor compliance with the procurement. Effect or potential effect: The procurement policy retained by the Organization has not been updated to confirm to the Organization’s current operations. The Organization could become noncompliant with the requirements of the Uniform Guidance, resulting in findings and questioned costs related to dollar amounts being expended to vendors. Additionally, the Organization could become ineligible to receive funds from federal entities or may have to issue refunds to federal entities. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should update its procurement policy to reflect current operations. Additionally, the Organization should review the current procurement operations in conjunction with the review of the procurement policies to ensure that all practices and policies conform to the standards promulgated by the CFR. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2021-005