2022-003 Procurement, Suspension and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20560 / 12060-SDE64370-20508 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. Condition: EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None Context: Although EASTCONN did not have a policy in place in conformity with the Federal Uniform Guidance criteria, EASTCONN did follow its own procedures as it relates to the contracts under the procurements applicable to EASTCONN?s major programs. Cause: EASTCONN did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that EASTCON review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with this finding.
2022-003 Procurement, Suspension and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20560 / 12060-SDE64370-20508 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. Condition: EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None Context: Although EASTCONN did not have a policy in place in conformity with the Federal Uniform Guidance criteria, EASTCONN did follow its own procedures as it relates to the contracts under the procurements applicable to EASTCONN?s major programs. Cause: EASTCONN did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that EASTCON review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with this finding.
2022-003 Procurement, Suspension and Debarment Federal Agency: United States Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20560 / 12060-SDE64370-20508 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. Condition: EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None Context: Although EASTCONN did not have a policy in place in conformity with the Federal Uniform Guidance criteria, EASTCONN did follow its own procedures as it relates to the contracts under the procurements applicable to EASTCONN?s major programs. Cause: EASTCONN did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that EASTCON review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management agrees with this finding.
2022-003 FINDING Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction 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 FINDING Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction 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 FINDING Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction 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.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Airport Improvement Program Federal Financial Assistance Listing No.: 20.106 Federal Agency: U.S. Department of Transportation Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Special Tests & Provisions ? Wage Rate Requirements Grant Award Number: Applies to all awards with findings and no specific grant award Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 OMB Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition Found: As a result of our audit procedures, we noted 13 out of 60 certified payroll reports selected for testing were not submitted timely (weekly). The total population subject to this requirement was 359 certified payroll reports. Cause: The condition is caused by the County not having policies and procedures in place to comply with the wage rate requirements. Effect: The County does not have an effective internal control in place to ensure contractors and subcontractors are submitting certified payroll reports on a timely basis; thus, increasing the risk of the County?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 certified payroll reports were selected from a population of 359. Of the 60 certified payroll reports tested, a total of 13 were not submitted timely (weekly). Repeat Finding from Prior Year(s): Yes, prior year finding 2021-014. Recommendation: We recommend that Airport implement policies and procedures to review certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: 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 non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain 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. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: 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 non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain 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. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
2022-001 Department of Education CFDA # 84.425F ? Education Stabilization Fund - Institutional Award Number P425F202362 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls 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 depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Cause: Based on limited federal funding previously received that would require a written policy and lack of awareness or understanding of all of the specific requirements under the Uniform Guidance specific to written policy requirements over procurement, suspension and debarment. Effect: A lack of established controls increases 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: A nonstatistical sample of 3 vendors out of 5 vendors that meet thresholds required for procurement and suspension debarment testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the University implement a procurement policy as required under Uniform Guidance with the required components that can be used if future federal assistance is received. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-003: Procurement & Suspension and Debarment Material weakness in internal control over Procurement & Suspension and Debarment and Noncompliance U.S. Department of Treasury; Coronavirus State Local Fiscal Recovery Funds (SLFRF) passed through Fresno County. AL No. 21.027. Questioned Cost: Not applicable How the Questioned Cost was Computed: Not applicable Condition: C&M identified that the FCFPD did not have adequate written policies and did not maintain a written code of standard selection procedures for procurement transactions that included all the requirements of the Uniform Guidance. C&M identified a lack of adequate knowledge and experience of key procurement managers in light of responsibilities for procurements for Federal awards. In addition, the costs charged to the program included fuel cost incurred by FCFPD. The fuel cost had been procured from a couple vendors. The FCFPD stated the selection of these vendors was based on past experience and was not able to provide C&M with support of a noncompetitive procurement process that complies with 2 CFR 200 standards. Also, there was no evidence that FCFPD verified that vendors were not suspended or debarred or otherwise excluded from participating in the transactions before entering into the transaction with them. Criteria: The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, section 318(i) (Uniform Guidance) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. The records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contractor type, contractor selection or rejection, and the basis for the contract price. In addition, the Uniform Guidance, 2 CFR Part 200, section 200.118 states that the non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 and must use their own documented procurement procedures that must conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The FCFPD?s procurement policy is limited to establishing a guideline on spending and purchasing authority limits. There was a lack of understanding of federal laws and regulations relating to this requirement. Management did not have an understanding of the requirements for procurement and suspension and debarment. Effect: Procurements were made following a noncompetitive process that were not adequately documented and FCFPD could enter into transactions with vendors that are suspended of debarred. Costs charged to the Program could be disallowed. Recommendation: C&M recommends the FCFPD establish written procurement policies and procedures as required by the Uniform Guidance. The FCFPD should consider implementation of the following internal controls: 1. Review the Uniform Guidance and update the current policies and procedures to include all the requirements not part of the FCFPD?s current policies. 2. Make available the updated policies and procedures to responsible management and employees. 3. Management should monitor compliance and performance with the policies and procedures. View of Responsible Officials: Management agrees with the finding and has provided the accompanying corrective action plan.
Criteria or specific requirement: Per procurement standards, nonfederal entities other than States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. Per 2 CFR Section 200.319, procurement expenditures require documentation over the bidding process. Condition: During our testing, we identified transactions which the Organization contracted with a vendor for services that exceeded the $3,000 threshold (the Organizations? requirement per their procurement policy) and did not retain documentation for the bidding process for these services. Questioned costs: N/A Context: During our testing, we identified transactions which the Organization contracted with a vendor for services that exceeded the $3,000 threshold (the Organizations? requirement per their procurement policy) and did not retain documentation for the bidding process for these services. Cause: Client did not have a consistent process for ensuring the procurement processes were followed. Effect: Noncompliance could result in the Organization not obtaining the best pricing and spending the federal funds appropriately. Recommendation: We recommend that the Organization implement processes and procedures to ensure that all disbursements charged to the federal follow the proper procurement standards and to maintain support for the procurement methods used. Management Response: The Organization is reviewing and modifying the Purchase Requisition and Purchase Order Policy to reflect current practices more accurately, update federal regulations and associated purchase thresholds. In addition, the Organization is improving internal procedures to manage requisition submittals which reach thresholds that would dictate multiple bid submittals as well as ensure an annual training of the Organization?s management and purchasers on policy parameters.
Criteria: Per procurement standards, nonfederal entities other than States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. Per 2 CFR Section 200.319, procurement expenditures require documentation over the bidding process. Condition: During our testing of contracts above $25,000 to ensure that vendors are properly vetted to not be on the SAM.gov debarred vendors listing we noted no support showing that vendors were reviewed against the debarred vendors listing prior to entering into a contract. Questioned costs: N/A Context: During our testing of contracts above $25,000 to ensure that vendors are properly vetted to not be on the SAM.gov debarred vendors listing we noted no support showing that vendors were reviewed against the debarred vendors listing prior to entering into a contract. Cause: General error in lack of vendor verification due to lack of an oversight process in place. Effect: Debarred vendors could be used without proper verification. Recommendation: We recommend that the Organization implement processes and procedures to ensure that all vendors are reviewed against the debarred vendors listing prior to entering into the contract. Management Response: The Organization currently utilizes a third-party vendor, Compliatric, to screen vendors in accordance with SAM.gov requirements on a routine basis. However, a procedure does not currently exist to ensure 100% of new vendors are entered into this separate system. A procedure is being developed to ensure that all new vendors are entered into Compliatric and screening is completed prior to entering into a contract.
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.