Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within the Uniform Guidance. Condition The City’s procurement standards do not include all the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs None noted. Context Although the City did not have a policy in place in conformity with the federal Uniform Guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City’s major programs. Effect The City is at risk for noncompliance for expenditures of federal monies as it relates to federal procurement. Cause The Purchasing department staffing levels and timing of new hires did not allow for a complete review and update of the City’s purchasing policy. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with each of the criteria as set out in 2 CFR sections 200.318 through 200.326. Views of responsible official and planned corrective actions Management agrees with this finding as applies to the entirety of fiscal year 2023-2024. A comprehensive Purchasing Policy which includes all the essential elements as outlined in 2 CFR sections 200.318 through 200.326 was issued during the fiscal year 2023-2024. The Policy states that “The City of West Haven procurement process is guided by the Federal Code of Federal Regulations (“CFR”) sections 200.317 through 200.326.” The Purchasing Policy serves as a comprehensive guide for employees, clearly outlining the required procedures for acquiring goods, services, and equipment necessary for City operations. The City’s procurement process adheres to local ordinances, state statutes, tribal laws, and federal regulations, including the City Charter and Code (Section 42) and CFR Sections 200.318-200.326. Furthermore, the Purchasing Department continuously monitors the performance of the procurement program to ensure compliance with all applicable regulations. Any employee inquiries or concerns regarding procurement processes should be directed to the Purchasing Department or the Finance Director.
2024-001: Lack of Documentation for Procurement, Suspension and Debarment Testing Federal Department: Department of Labor Assistance Listing #: 17.274 Material Weakness in Internal Controls and Noncompliance Category of Finding – Procurement, Suspension, and Debarment Criteria - Uniform Guidance and 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 - There was no documentation maintained related to the search for price comparisons or suspension and debarment testing performed on vendors. Context – It was communicated by management during audit fieldwork that there was no documentation maintained related to the search for price comparisons or suspension and debarment testing performed on vendors. Cause – Management was in the process of implementing the draft procurement policy as of June 30, 2024. The policy is properly designed and follows the Uniform Guidance. However, the policy was just not implemented during the period under audit. Effect - Increased overall risk that Change Inc. is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services. Recommendation - We recommend that management implement a process to perform price comparisons and suspension and debarment testing as required by their procurement policy, and that as part of this process they maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections. This could include the use of standard forms and templates for purchase orders, contracts, cost/price analyses, bid evaluation, and suspension & debarment testing. Auditee’s comments and response – Management is in agreement with this finding. The Executive Director and Controller developed an updated procurement policy. This policy went into effect on July 1, 2024, and has been implemented throughout the organizational system. Responsible party for corrective action: Jill Johnson, Executive Director Repeat Finding: 2023-002
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE 2024-008: U.S. Department of the Treasury ARPA Coronavirus State and Local Recovery Funds, ALN 21.027 Procurement, Suspension, and Debarment Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform guidance) requires non-federal entities other than States to follow 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 sections 200.318 through 200.326. This includes using the small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(b). Condition, Cause, and Effect/Potential Effect: Internal controls at the County were not sufficient to ensure full and open competition on grant-funded contracts. Individuals involved in the procurement process incorrectly relied on NRS requirements instead of the County’s procurement policy and federal procurement guidelines. Questioned Costs: None noted. Context: A nonstatistical sample of the procurement transactions funded with the ARPA Coronavirus State and Local Recovery Funds revealed that the County did not conduct procurement transactions in a manner providing on two construction contracts. Recommendation: We recommend that the County provide additional training to grantoversight personnel and ensure controls are sufficiently enhanced to ensure procurement policies are followed on federal grant-funded purchases. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and will enhance control procedures as recommended. Repeat Finding from Prior Year: No
REFERENCE: 2024-101 CFDA NUMBER 84.425U – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2024 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425U210038 QUESTIONED COSTS N/A CONDITION The two construction contracts executed during fiscal year 2023-2024, did not include the provisions required under the Davis-Bacon-Act. Accordingly, weekly certified payroll reports were not obtained or reviewed. CRITERIA In accordance with Title 2 of the Code of Federal Regulations, Subtitle A Office of Management and Budget Guidance for Grants and Agreements, Chapter II Office of Management and Budget Guidance, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Appendix II to Part 200 – Contract Provisions for non-Federal Entity Contracts Under Federal Awards, In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (D), Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. In accordance with the OMB Compliance Supplement, Part 4 – Wage Requirements Cross-Cutting Section, 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). In accordance with OMB Compliance Supplement, Part 6 – Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School did not ensure that the construction contractor complied with Davis-Bacon-Act (prevailing wage requirements). CAUSE Training over Davis-Bacon-Act requirements was not completed by the appropriate personnel. Accordingly, internal controls were not designed appropriately to ensure that the vendors were notified of the contracts being funded with federal monies and that prevailing wage requirements had to be complied with. RECOMMENDATION AND BENEFIT A control system should be developed and implemented to ensure that the contracts funded with federal monies contain the appropriate provisions to comply with the Davis-Bacon-Act requirements. Additionally, procedures should be established to obtain and review weekly certified payroll reports for construction services funded with federal monies. All documentation supporting prevailing wages requirements should be retained. This will help ensure that program requirements are complied with. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
.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) Child Nutrition Cluster: School Breakfast Program (10.553) National School Lunch Program (10.555) 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 School’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The School also has procedures to identify procurement transactions requiring competitive bids or proposals. Context and Condition - We selected three contracts to test for compliance with procurement standards. Records for one contract lacked documentation sufficient to detail procurement history. Upon further investigation, the School determined that the vendor in question was a fraudulent vendor and transactions charged to this vendor for the program were all fraudulent charges. Of the $738,725 charged to the child nutrition program on the Annual Program Report (APR) submitted to the Utah State Board of Education for the year ended June 30, 2024, $62,246 (8%) were fraudulent charges. Cause - The School did not follow its documentation policy for obtaining contracts or bids. Effect - The School paid this vendor $62,246 for goods that were not provided during the year ended June 30, 2024. Questioned Costs - $62,246 – This amount represents the costs that were charged to the federal award but did not meet program requirements and are considered fraudulent transactions. Repeat finding - No Statistically valid - Yes Recommendation - We recommend the School ensures it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Views of responsible officials - The School will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified.
.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) Child Nutrition Cluster: School Breakfast Program (10.553) National School Lunch Program (10.555) 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 School’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The School also has procedures to identify procurement transactions requiring competitive bids or proposals. Context and Condition - We selected three contracts to test for compliance with procurement standards. Records for one contract lacked documentation sufficient to detail procurement history. Upon further investigation, the School determined that the vendor in question was a fraudulent vendor and transactions charged to this vendor for the program were all fraudulent charges. Of the $738,725 charged to the child nutrition program on the Annual Program Report (APR) submitted to the Utah State Board of Education for the year ended June 30, 2024, $62,246 (8%) were fraudulent charges. Cause - The School did not follow its documentation policy for obtaining contracts or bids. Effect - The School paid this vendor $62,246 for goods that were not provided during the year ended June 30, 2024. Questioned Costs - $62,246 – This amount represents the costs that were charged to the federal award but did not meet program requirements and are considered fraudulent transactions. Repeat finding - No Statistically valid - Yes Recommendation - We recommend the School ensures it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Views of responsible officials - The School will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified.
United States Department of Housing and Urban Development Passed through from: NYC Housing and Preservation Department Assistance Listing No. 14.267 Continuum of Care Criteria: As required by the 2 CFR section 200.318 through 200.326, nonfederal entities must follow the procurement standards required by that section in accordance with the Uniform Guidance. Condition: The Organization did not adhere to their policy when selecting a vendor to purchase goods at their residential locations. In addition, the procurement policy of the Organization does not align with all requirements under the Uniform Guidance. Cause: The Organization did not bid or procure for purchases of goods at their Euclid and Westbourne locations. Due to familiarity with the vendors, the Organization has been using them for the purchase of these goods and has not adhered to their procurement policy. Effect: The Organization is not adhering to their procurement policy and is not using a bidding process for the purchase of their goods. Context: We selected 4 vendors used that would require procurement procedures to obtain documented price or rate quotations from a number of qualified sources for testing whose purchases totaled approximately $57,000 to $165,000 for the fiscal year. The Organization could not provide us with the required documentation needed to comply with the Uniform Guidance. Recommendation: We recommend that the Organization review and update its procurement policy to align with what is required by the Uniform Guidance and procure all goods, services and material purchases greater than the threshold outlined in the then revised procurement policy and in accordance with Uniform Guidance. Views of Responsible Officials: The Organization has engaged a professional services firm in a consulting engagement to review and assist in revising their procurement policy to align its policies and procedures for procurement with Uniform Guidance.
United States Department of Housing and Urban Development Passed through from: NYC Housing and Preservation Department Assistance Listing No. 14.267 Continuum of Care Criteria: As required by the 2 CFR section 200.318 through 200.326, nonfederal entities must follow the procurement standards required by that section in accordance with the Uniform Guidance. Condition: The Organization did not adhere to their policy when selecting a vendor to purchase goods at their residential locations. In addition, the procurement policy of the Organization does not align with all requirements under the Uniform Guidance. Cause: The Organization did not bid or procure for purchases of goods at their Euclid and Westbourne locations. Due to familiarity with the vendors, the Organization has been using them for the purchase of these goods and has not adhered to their procurement policy. Effect: The Organization is not adhering to their procurement policy and is not using a bidding process for the purchase of their goods. Context: We selected 4 vendors used that would require procurement procedures to obtain documented price or rate quotations from a number of qualified sources for testing whose purchases totaled approximately $57,000 to $165,000 for the fiscal year. The Organization could not provide us with the required documentation needed to comply with the Uniform Guidance. Recommendation: We recommend that the Organization review and update its procurement policy to align with what is required by the Uniform Guidance and procure all goods, services and material purchases greater than the threshold outlined in the then revised procurement policy and in accordance with Uniform Guidance. Views of Responsible Officials: The Organization has engaged a professional services firm in a consulting engagement to review and assist in revising their procurement policy to align its policies and procedures for procurement with Uniform Guidance.
2024-006 - Wage Rate Compliance Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Award year and number: 2024 Criteria or Specific Requirement: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). 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). Non-federal 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 non-Federal 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: The District did not comply with the wage rate compliance related to construction projects for expenditures paid from Impact Aid monies. Context: During the testing of significant claims for the Impact Aid related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Questioned Costs: To be determined by grantor. Effect: The District could potentially be misspending Impact Aid construction monies that were received. Cause: The District was aware of the compliance requirement, as it was included in the documented contract request for proposal, which stated that the prevailing wage rate needed to be paid. However, the contract was awarded to a two-member partnership in which the partners do all the work and do not pay salaries and had no subcontractors. As a result, the District and the contractors were unsure how to proceed with compliance with wage rate requirements and no payroll certification was completed. Auditor's Recommendation: To ensure compliance with Wage Rate Requirements, the District should review and update contracting procedures to clearly state prevailing wage rate requirements. Training sessions and guidance should be provided to contractors and subcontractors, especially those without traditional payroll structures. The District should establish a monitoring system to review certified payrolls and conduct periodic audits. In unclear cases, the District should seek guidance from the Department of Labor. Enhancing communication channels between the District, contractors, and subcontractors will help address compliance issues promptly. Implementing these steps will ensure proper use of Impact Aid construction funds. View of Responsible Official: The District has created a standard operating procedure document to follow for all construction projects. The District will also share that document with all contractors to help communicate the needs of the District regarding construction projects. If necessary, the District will provide the contractor with training to make sure all payrolls are properly certified and in compliance with applicable law. The District will also create a shared Google document for each construction project to manage the progress and payments.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 Organization 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 Year: 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: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. In addition, there was no review of contracts entered into to ensure they included all requirements of the applicable CFR. 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 compliance policies increases the overall risk of non-compliance. Questioned Costs: None reported. Context/Sampling: Overall procurement policy. Repeat Finding from Prior Year: No. Recommendation: We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 Organization 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 Year: 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: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. In addition, there was no review of contracts entered into to ensure they included all requirements of the applicable CFR. 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 compliance policies increases the overall risk of non-compliance. Questioned Costs: None reported. Context/Sampling: Overall procurement policy. Repeat Finding from Prior Year: No. Recommendation: We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 Organization 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 Year: 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: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. In addition, there was no review of contracts entered into to ensure they included all requirements of the applicable CFR. 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 compliance policies increases the overall risk of non-compliance. Questioned Costs: None reported. Context/Sampling: Overall procurement policy. Repeat Finding from Prior Year: No. Recommendation: We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 Organization 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 Year: 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: Management agrees with the finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 All Awards State and Local Fiscal Recovery Funds 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 there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. In addition, there was no review of contracts entered into to ensure they included all requirements of the applicable CFR. 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 compliance policies increases the overall risk of non-compliance. Questioned Costs: None reported. Context/Sampling: Overall procurement policy. Repeat Finding from Prior Year: No. Recommendation: We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
Criteria or specific requirement: Per 2 CFR section 200.326, 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. Condition: The contracts and subcontracts did not include the required prevailing wage rate provisions. Context: For all 11 contracts tested, prevailing wage rate clauses were missing in both the contracts or subcontracts. However, the City did obtain certified weekly payrolls from all contractors tested. Questioned costs: Undetermined. Cause: The City failed to adhere to established internal controls over wage rate requirements and related regulations. Effect: Excluding the required prevailing wage rate information in contracts and subcontracts may cause vendors to be uninformed about specific program regulations that apply to the funds they receive. Recommendation: The City should review and enhance its policies and procedures to ensure that all required wage rate provisions are consistently included in contracts and subcontracts. Views of responsible officials: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation of the evaluation each proposal received and reason for selection of the winning bid for the procurement of a consulting firm to conduct the site selection study for the Woodland Transit Center project. The District also did not include a Debarment and Suspension clause in the request for proposal or contract and did not require a certificate confirming the contractor was not debarred in the final agreement. The District was not able to find records of the District verifying that the awarded consulting firm is not on the governmentwide exclusions in the System for Award Management (SAM). Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following: Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.” Section 200.318(i) states that “The non-Federal entity 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.” Section 200.327 states that “The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II of this part.” Appendix II(H) includes “Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.” Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the Uniform Guidance requirement to maintain documentation of procurement procedures. Context: The original procurement for the consulting firm for the Woodland Transit Project was performed in late December 2017 and awarded in January 2018 and then extended during 2024. This procurement precedes the current staff. It was verified the contractor selected was not debarred during the 2024 single audit. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of the proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.
Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement and 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. Condition The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. Context The sample was not intended to be, and was not, a statistically valid sample. During our review of disbursements, we noted the following: The School did not maintain suspension and debarment for purchases over $25,000 during the year. For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained. For three sealed proposals reviewed, the District did not maintain documentation. For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.
Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement and 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. Condition The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. Context The sample was not intended to be, and was not, a statistically valid sample. During our review of disbursements, we noted the following: The School did not maintain suspension and debarment for purchases over $25,000 during the year. For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained. For three sealed proposals reviewed, the District did not maintain documentation. For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.732 Award Numbers and Years: All awards Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity 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 requirement identified in 2 CFR Part 200. Condition/Context The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source. Cause The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance. Effect The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance. Questioned Costs $0 Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.732 Award Numbers and Years: All awards Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity 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 requirement identified in 2 CFR Part 200. Condition/Context The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source. Cause The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance. Effect The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance. Questioned Costs $0 Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Number: 2024-002 Repeat Finding: Yes – 2023-001, 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X132, AZ-90-X-143, AZ-2018-003-00, AZ-2019-010-00, AZ-2019-035, AZ-2019-036 AZ-2023-001-00 N/A Formula Grants for Rural Areas and Trial Transit Program 20.509 CA-2022-231-00, GRT-22-0008862-T N/A Federal Agency: Department of Transportation Pass-Through Agencies: Arizona Department of Transportation, Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness 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. The Board adopted a Policies and Procedures Manual that requires formal bid procedures for purchases over $100,000. Condition The Authority did not follow its Board adopted Policies and Procedures Manual or federal regulations. Cause YCIPTA was operating under an expired contract and did not follow Board-adopted policies. Effect YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. Context For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid of proposal. The sample was not intended to be, and was not, a statistically valid sample. Recommendation YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. Views Of Responsible Officials See Corrective Action Plan.
Finding Reference 2024-03 Assistance Listing Number 20.205 Highway Planning and Construction (Federal-Aid Highway Program) Name of Federal Agency Department of Transportation Compliance Requirement Special Tests and Provisions – Wage Rate Requirements Type of Finding: Significant Deficiency on Internal Control and Noncompliance Condition: From a sample of twenty-five payroll periods of construction projects examined, we noticed the following: 1) For one construction project, the contractor's payroll for the week of July 3, 2023, through July 9, 2023, was certified on July 27, 2023, exceeding the weekly certification requirement outlined in the Uniform Guidance. 2) For one construction project, the subcontractor's payroll for the week of July 3, 2023, through July 9, 2023, was certified on August 4, 2023, exceeding the weekly certification requirement outlined in the Uniform Guidance. 3) For one construction project, the contractor’s payroll for the week of November 13, 2023, through November 19, 2023, was certified on November 27, 2023, exceeding the weekly certification requirement outlined in the Uniform Guidance. 4) For one construction project, the contractor’s payroll for the week of June 24, 2024, through June 30, 2024, was certified on July 17, 2024, exceeding the weekly certification requirement outlined in the Uniform Guidance. This is a repeat finding from prior year 2023. Although this finding was originally not reported in the 2023 Single Audit Report, during the current audit, we became aware that this issue also involved 2023. Therefore, the 2023 Single Audit Report is in the process of being reissued. In the reissued 2023 Single Audit Report, the finding will be identified as No. 2023-05. Criteria: In accordance with the 2024 Compliance Supplement: 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). Cause: The delays in the certification of payroll weeks are due to several factors, including: Inefficient payroll processing procedures within the contractor or subcontractor's system. Lack of oversight and monitoring by the Authority to ensure timely certification of payrolls. Miscommunication between the contractor, subcontractor, and the Authority regarding certification deadlines. Effect: The failure to certify payrolls on a weekly basis as required by federal regulations can lead to noncompliance with federal regulations, specifically the Davis-Bacon Act and related Department of Labor (DOL) regulations and increased risk of wage underpayments or miscalculations, which may result in financial liabilities for the entity. Questioned Costs: None Recommendation: To address the identified issues, the following corrective actions are recommended: Implement a Payroll Monitoring System: Establish automated tracking mechanisms to ensure payrolls are certified and submitted within the required weekly timeframe. Enhance Oversight and Compliance Reviews: Designate a compliance officer or team responsible for verifying that certified payrolls are submitted on time. Perform regular internal audits to identify and correct compliance issues promptly. Provide Training for Contractors and Subcontractors: Conduct mandatory training sessions on Davis- Bacon Act requirements and payroll certification processes. Ensure all responsible staff understand the federal regulations governing wage rate compliance. Improve Communication Between Stakeholders: Establish clear communication channels between contractors, subcontractors, and the Authority. Require periodic status updates to ensure timely payroll submission. Views of Responsible Officials Refer to Management’s unaudited corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-003 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) 40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to 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. 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: In March 2024, the City implemented procedural changes to their certified payroll review process. Until February 2024, the City did not retain evidence to document the individual who reviewed the certified payroll for each week in which work was performed by construction contractors and subcontractors. Due to backlog, the City was not able to catch up on certifications until August 2024 which was after the fiscal year had ended. For fifty-four (54) of sixty (60) weeks of certified payroll submissions selected for testing, we noted that the City did not review the contractors’ submissions of certified payroll in a timely manner. For six (6) out of sixty (60) weeks of certified payroll submissions selected, we noted that a statement of non-performance was submitted. However, the tracking spreadsheet provided to the City by its 3rd party project manager indicated that work had been performed. For nineteen (19) out of sixty (60) weeks of certified payroll submissions selected, we noted that the contractor or subcontractor had not submitted the weekly certified payroll in a timely manner. The contractor had submitted their certified payroll several weeks after the week of work performed. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the accuracy of the tracking of work weeks being performed as well as the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective controls over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected sixty (60) out of all weeks indicated as work weeks for the City’s project for testing. However, due to the condition noted above, the population of work weeks could not be verified. Repeat Finding from the Prior Year(s): Yes, 2023-003. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing No. 10.557 U.S. Department of Agriculture Criteria or Specific Requirement – Procurement (45 CFR 200.318-200.326) Condition - The Health System, prior to fiscal year 2025, did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. In addition, the Health System entered into various professional services contracts for marketing, advertising, and information dissemination that do not exceed the simplified acquisition threshold and are considered micro-purchases, but did not maintain appropriate documentation to document the price reasonableness based on research, experience, and purchase history to support its procurement decisions. Questioned Costs - None Context - We tested one out of a total of four contracts that were considered micro-purchases. The sample was not intended to be, and was not, a statistically valid sample. During our testing of procurement requirements, the two vendor contracts tested over the micro-purchase threshold did not have appropriate documentation to evidence the basis of vendor selection (documentation of the price reasonableness based on research, experience, and purchase history). Effect - Micro-purchases were made without appropriate documentation to comply with Uniform Guidance requirements. Cause - The Health System did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. Adequate supporting documentation on the procurements were not obtained or maintained within vendor files and vendor contracts do not contain the necessary contract provision and language required by the Uniform Guidance. Repeat Finding - Yes Recommendation - We recommend the Health System revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. We also recommend the Organization perform a comprehensive review of its procurement policy and ensure that it is in compliance and in-line with the procurement requirements of the Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has developed and implemented a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.
Procurement, Suspension and Debarment Criteria Procurement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow specific procurement standards set out in 2 CFR sections 200.317 through 200.327, which includes documenting the procurement methods used for vendor selection. These procedures are designed to ensure fair competition, cost-effectiveness, and federal requirements. These procurement standards require, among other provisions, that a non-federal entity must: 1. 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 reliable contractors, and maintaining records to document the history of procurement. 2. Conduct all procurement transactions for the acquisition of property or services under a federal award in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. 3. Use documented procurement procedures, consistent with the standards of 2 CFR 200.317 to 320. 2 CFR 200.320 enumerates below the different procurement methods that a non-federal entity should use: a) 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 $50,000. b) Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. c) 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)). 4. 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) (1); 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)). 5. 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)). 6. 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 (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (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 During our audit, MARTA was unable to provide purchase order documentation or contract for eight samples that are above $500. Per current procurement policy, “Purchases of supplies, services, and equipment costing more than five hundred ($500) shall be made by purchase order, unless authorized by a signed contract or Mountain Transit Board Approval”. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the required price or rate quotations for those purchases or contracts with contract amounts above $10,000 were obtained from an adequate number of qualified sources and maintained the documentation to support its conclusion. These were noted for two samples tested. The expenditure paid ranged from $10,000 to $36,000 in 2024. During our audit, MARTA was unable to provide supporting documentation to demonstrate that the process of verifying if vendors are not suspended or debarred was performed on two vendors tested. The expenditure paid to these vendors ranged from $109,000 to $647,000 in 2024. Cause MARTA did not follow its existing purchasing policy and procedures, and lack of procedures in maintaining appropriate records of vendor selection and compliance with procurement standards. Effect The absence of procurement documentation raises the risk of non-compliance with federal regulations, which could lead to potential disallowances or unnecessary sanctions. Questioned Costs None Recommendation MARTA should strengthen its internal controls over procurement by ensuring that all procurement activities, particularly significant expenditures, are properly documented. This includes retaining evidence that procurement methods required by the Uniform Guidance were followed, such as bids, contracts, or justifications for sole-source vendors. MARTA should also conduct training for staff involved in procurement to ensure awareness and adherence to the policies. Regular internal audits may be implemented to verify compliance with procurement procedures. Views of Responsible Officials and Planned Corrective Action MARTA is in the process of updating the Procurement Policy. MARTA will ensure that updated policies and procedures will be implemented to address compliance and documentation requirements for small and micro-purchases, sole-source, and informal processes. The updated Procurement Policy will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025