Finding 2024-003: Material Weakness – Controls and Compliance over Special Tests and Provisions Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: Certified payrolls were not obtained or reviewed by the District. Program expenditures for fiscal 2024 included one construction contract. Cause: The District was not aware of this specific requirement. Effect: Federal funds may be paid to a contractor or subcontractor that pays wages less than the prevailing wage rates. Questioned Costs: None noted. Recommendation: We recommend that the District implement a process to obtain certified payrolls when using federal funds on construction contracts. Once the certified payrolls are obtained, the District should review them as outlined by the applicable federal regulations and retain documentation of their conclusion. Views of responsible officials: The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District has since received and reviewed the certified payrolls and determined the contractor is in compliance.
U.S. Department of Education passed through State of Utah Board of Education 2024-001 Procurement and Suspension and Debarment Program Name of Federal Program (Assistance Listing Number): Substance Abuse and Mental Health Services Projects of Regional and National Significance (93.243) Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). The District’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The District also has procedures to identify procurement transactions requiring competitive bids or proposals. Context and Condition: We selected six contracts to test for compliance with procurement standards. Records for four contracts lacked documentation sufficient to detail procurement history. Cause: The District did not follow its documentation policy for obtaining contracts or bids. Effect: A potential failure to conduct procurement transactions in a manner providing full and open competition exists. Questioned Costs: No costs were questionable Recommendation: We recommend the District ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Views of responsible officials: The District will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified.
Finding 2024-003: Material Weakness - Internal Control and Compliance Over Special Tests and Provisions Program: COVID-19: Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146 and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: The District did not enter into a contract with the primary contractor for the HVAC construction project paid for with federal assistance funds, nor did the District verify that prevailing wage rate requirements were included in subcontracts. Additionally, the District does not have controls in place to track weekly certified payrolls. Cause: The District did not have controls in place to ensure federal requirements were met in the process for selecting contractors and monitoring subcontractors. The District also does not have a process in place to track the weekly certified payrolls. Effect: Federal Funds may be paid to a contractor that does not follow prevailing wage laws. Questioned Costs: Not determinable. Recommendation: We recommend the District implement a system for procurement procedures to ensure contacts are obtained and include the required prevailing wage rate requirements. This should also include monitoring all subcontractors to ensure they meet these requirements. We also recommend the District implement a system to track weekly certified payrolls to ensure all payrolls are received. Views of Responsible Officials: The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.
Finding 2024-003: Material Weakness - Internal Control and Compliance Over Special Tests and Provisions Program: COVID-19: Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Agency: Wisconsin Department of Public Instruction Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146 and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition/Context: The District did not enter into a contract with the primary contractor for the HVAC construction project paid for with federal assistance funds, nor did the District verify that prevailing wage rate requirements were included in subcontracts. Additionally, the District does not have controls in place to track weekly certified payrolls. Cause: The District did not have controls in place to ensure federal requirements were met in the process for selecting contractors and monitoring subcontractors. The District also does not have a process in place to track the weekly certified payrolls. Effect: Federal Funds may be paid to a contractor that does not follow prevailing wage laws. Questioned Costs: Not determinable. Recommendation: We recommend the District implement a system for procurement procedures to ensure contacts are obtained and include the required prevailing wage rate requirements. This should also include monitoring all subcontractors to ensure they meet these requirements. We also recommend the District implement a system to track weekly certified payrolls to ensure all payrolls are received. Views of Responsible Officials: The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
2024-004 Department of Agriculture, Passed through Minnesota Department of Education Federal Financial Assistance Listing 10.553/10.555C/10.555/10.559/10.582 Child Nutrition Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.371C Comprehensive Literacy Development Procurement, Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension and debarment it was identified that the District’s micropurchase threshold did not satisfy the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – No. Recommendation - We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of responsible officials - There is no disagreement with the finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.
Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.