Condition and context ? The reports for the quarter ended December 31, 2021, for the Coronavirus State and Local Fiscal Recovery Funds and the Health Center Program Cluster, and the report for the quarter ended September 30, 2021 for the Emergency Rental Assistance Program were issued a day after the deadline. In addition, for one of three programmatic reports tested for the Emergency Rental Assistance Program, the report showed the number of participating households and funds paid at zero for each when it should have been 512 households and $646,914 paid, respectively.Effect ? The effect of the reporting delays and incorrect information is that funding agencies are receiving incorrect or untimely information.Cause ? The cause is insufficient monitoring of reporting deadlines and inadequate review process of reports prior to their submittal.Criteria ? Federal regulations (2 CFR ?200.327) and the terms of the federal grants and contracts require that financial reports be filed in a timely manner and be supported by accurate documentation.Recommendation ? We recommend that the County improve controls over grant reporting that includes a process for identifying reporting requirements and monitoring the timely grant reporting. The system of control should include evaluating and documenting the reporting requirements of each grant and, assignment of both the employees responsible for preparation of the grant reports and a secondary employee assignment for overall monitoring of the timeliness of all grant reports.
Condition and context ? The reports for the quarter ended December 31, 2021, for the Coronavirus State and Local Fiscal Recovery Funds and the Health Center Program Cluster, and the report for the quarter ended September 30, 2021 for the Emergency Rental Assistance Program were issued a day after the deadline. In addition, for one of three programmatic reports tested for the Emergency Rental Assistance Program, the report showed the number of participating households and funds paid at zero for each when it should have been 512 households and $646,914 paid, respectively.Effect ? The effect of the reporting delays and incorrect information is that funding agencies are receiving incorrect or untimely information.Cause ? The cause is insufficient monitoring of reporting deadlines and inadequate review process of reports prior to their submittal.Criteria ? Federal regulations (2 CFR ?200.327) and the terms of the federal grants and contracts require that financial reports be filed in a timely manner and be supported by accurate documentation.Recommendation ? We recommend that the County improve controls over grant reporting that includes a process for identifying reporting requirements and monitoring the timely grant reporting. The system of control should include evaluating and documenting the reporting requirements of each grant and, assignment of both the employees responsible for preparation of the grant reports and a secondary employee assignment for overall monitoring of the timeliness of all grant reports.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.318 General Procurement Standards requires entities to have documented procurement procedures that conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Condition: The City does not have formal documented procurement policies and procedures related to expenditures of federal awards. Cause: The City Council forms a committee to review and approve disbursements of federal funds. This process is the City’s general practice but does not follow written procurement policies and procedures. Effect: The City is out of compliance with general procurement standards under 2 CFR 200.318. Recommendation: The City should adopt formal documented procurement policies and procedures related to expenditures of federal awards. Response: The City Clerk and Mayor, with help from the Treasurer, will develop and implement documented procurement procedures that conform to the procurement standards relating to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.317 through 200.327.
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.318 General Procurement Standards requires entities to have documented procurement procedures that conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Condition: The City does not have formal documented procurement policies and procedures related to expenditures of federal awards. Cause: The City Council forms a committee to review and approve disbursements of federal funds. This process is the City’s general practice but does not follow written procurement policies and procedures. Effect: The City is out of compliance with general procurement standards under 2 CFR 200.318. Recommendation: The City should adopt formal documented procurement policies and procedures related to expenditures of federal awards. Response: The City Clerk and Mayor, with help from the Treasurer, will develop and implement documented procurement procedures that conform to the procurement standards relating to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.317 through 200.327.
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.318 General Procurement Standards requires entities to have documented procurement procedures that conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Condition: The City does not have formal documented procurement policies and procedures related to expenditures of federal awards. Cause: The City Council forms a committee to review and approve disbursements of federal funds. This process is the City’s general practice but does not follow written procurement policies and procedures. Effect: The City is out of compliance with general procurement standards under 2 CFR 200.318. Recommendation: The City should adopt formal documented procurement policies and procedures related to expenditures of federal awards. Response: The City Clerk and Mayor, with help from the Treasurer, will develop and implement documented procurement procedures that conform to the procurement standards relating to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 200.317 through 200.327.
2022-003 Procurement Policies and Covered Transactions Compliance Requirement Procurement, Suspension, and Debarment Category Significant Deficiency in Internal Control and Noncompliance Federal Agency U.S. Department of the Treasury Pass-Through Entity Puerto Rico Fiscal Agency and Financial Advisory Authority ALN 21.027 Federal Program COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR section 200.318 General procurement standards. (a) 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 services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. 2 CFR section 180.220 Are any procurement contracts included as covered transactions? (a) Covered transactions under this part— (1) Do not include any procurement contracts awarded directly by a Federal agency; but (2) Do include some procurement contracts awarded by non-Federal participants in nonprocurement covered transactions. (b) Specifically, a contract for goods or services is a covered transaction if any of the following applies: (1) The contract is awarded by a participant in a nonprocurement transaction that is covered under § 180.210, and the amount of the contract is expected to equal or exceed $25,000. (2) The contract requires the consent of an official of a Federal agency. In that case, the contract, regardless of the amount, always is a covered transaction, and it does not matter who awarded it. For example, it could be a subcontract awarded by a contractor at a tier below a nonprocurement transaction, as shown in the appendix to this part. (3) The contract is for Federally-required audit services. (c) A subcontract also is a covered transaction if,— (1) It is awarded by a participant in a procurement transaction under a nonprocurement transaction of a Federal agency that extends the coverage of paragraph (b)(1) of this section to additional tiers of contracts (see the diagram in the appendix to this part showing that optional lower tier coverage); and (2) The value of the subcontract is expected to equal or exceed $25,000. Condition General Procurement Standards - Written Policies The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements. Suspension and Debarment - Covered Transaction From a population of nineteen disbursements, we selected nine disbursements to ascertain compliance with 2 CFR section 180.220 by examining the procurement documents provided by the Corporation. From that sample, we identified nine instances in which the SAM.gov registration verification process was not performed. Of the nine instances, we found eight suppliers properly registered, but one supplier appears as validated as unique and existing but not registered in SAM.gov. Cause Lack of understanding of procurement compliance requirements for federal awards. Fiscal year 2023 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs. Effect Noncompliance with sections 200.318 and 180.220 of 2 CFR may lead to temporary withholding of cash payments until the deficiency is corrected, and/or withholding further federal program awards. Questioned Costs None Recommendation General Procurement Standards - Written Policies and Suspension and Debarment - Covered Transaction We recommend the Corporation update its internal procurement written policies following the provisions of current state statutes and regulations and develop separate procurement written policies following the provisions of federal laws and regulations or the terms and conditions of federal awards, which includes the Procurement Standards described in 2 CFR section 200.317 through 200.327, as applicable. By updating, developing, and implementing the required written procurement policies, the Corporation will be able to comply with the federal government compliance requirements. Views of responsible officials Refer to Corrective Action Plan section.
Material Instance of Non-Compliance and Significant Deficiency Written Procurement Policy This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 10.555, Child Nutrition Cluster, funded by the U.S. Department of Agriculture and passed through by the Commonwealth of Massachusetts, Department of Elementary and Secondary Education (DESE). Criteria: The School must follow the procurement standards set out at 2 CFR sections 200.317 through 200.327. The School also must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: During our compliance testing, we reviewed the School's procurement policy against Uniform Guidance standards. The policy did not meet all of the considerations that are required through Uniform Guidance, Federal and state regulations. The School followed their procurement policy during fiscal year 2022, but should update this policy in accordance with these regulations. Cause: The School’s existing procurement policy did not document all of the elements required by the Uniform Guidance. Effect: Non-compliance with the Uniform Guidance, potentially resulting in an increase in questioned costs. Was the finding a repeat of a finding in the immediately prior year?: No Recommendation: AAFCPAs recommends that management revise their policy to comply with current standards under the Uniform Guidance. Management Response: During the audit, it was recognized that the School did not have an updated procurement policy to comply with the current standards under the Uniform Guidance. This is the first year that the School received funds that exceeded the Uniform Guidance threshold and was not aware that there was a difference between Federal policy and state policy that we operated under. During the audit, it was recognized that the School had obtained appropriate bids and performed an adequate and documented comparison of qualifications amongst vendors before selecting the current vendor. These practices, which are outlined in the Uniform Guidance Standard, although followed, are not accurately reflected in our current procurement policy. This policy will be updated during fiscal year 2023.
Finding 2022-011 - Noncompliance Over Procurement and Suspension and Debarment – Coronavirus State and Local Fiscal Recovery Funds PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) FEDERAL AWARD NUMBER: SLFRP3720 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Procurement and Suspension and Debarment QUESTIONED COSTS: $203,000 Condition: During our review of the disbursement data from Muskogee County regarding procurement and suspension and debarment as per the Uniform Guidance 2 CFR 200.317 through 200.327, we identified the following: • One (1) ambulance was purchased in the amount of $203,000 for the Muskogee County EMS. There were no bids or quotes provide by the County or found in the BOCC meeting minutes supporting expenditure documentation. • There were six (6) vendors, in which the County did not check the www.SAM.gov website to review if the vendor had been suspended or debarred for those disbursements that warranted a bid, on the 6-month bid list, or received quotes. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance of expenditures for all federal awards. Effect of Condition: This condition resulted in noncompliance to grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends county officials and department heads gain an understanding of federal programs awarded to Muskogee County. Internal control procedures should be designed and implemented to ensure accurate procurement and suspension and debarment and to ensure compliance with federal requirements. Management Response: Chairman of the Board of County Commissioners: Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended. This includes that all expenditures are properly documented and that all vendors are federally eligible to perform services. Criteria: 2 CFR § 200.317 through 200.327 General Procurement Standards reads as follows: When procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds. The State will comply with §§ 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by § 200.327. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in §§ 200.318 through 200.327. 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 services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. 2 CFR 180.700 – 180.760 Suspension and 2 CFR 180.800 – 180.885 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.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-002 Financial Statement Reconciliations/Tie-In Procedures Significant Deficiency CONDITION: A weakness existed in the overall reconciliation/tie-in procedures performed over the School’s financial statement accounts for the fiscal year ended June 30, 2022. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included:A) Beginning Balances B) Cash Balances C) Account Receivables D) Grant Receivables/Unearned Revenues E) Accounts Payable F) Grant Revenue CRITERIA: OMB Uniform Guidance states the following in section 200.302, “(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. CAUSE: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. EFFECT: In the course of performing the audit, the auditor recommended 10 adjusting journal entries be made to the financial statements for fiscal year ending June 30, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature.
2022-008 Procurement Policy and Procedures U.S. Department of Justice, Passed through Illinois Criminal Justice Information Authority Crime Victim Assistance – Assistance Listing Number 16.575 Criteria: Non-federal entities other than states must follow the procurement standards set out in 2 CFR sections 200.318 through 200.327. 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 Corporation does not maintain a formal procurement policy and procedures that meets the requirements of the Uniform Guidance, including procedures addressing allowable costs exceeding the small purchase threshold. The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Cause: The Corporation has not implemented a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. Effect: The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Questioned costs: None Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that the Corporation implement a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
2022 ? 004 ? Procurement and Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Assistance Listing Number: 84.425F Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: When procuring property and services under a Federal award, entities must follow the procurement standards outlined in 2 CFR 200.218 through 200.327. Included in these requirements, a 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. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, 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. Condition: The University has implemented formal, written policies and procedures to align with the requirements for procurement and suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 5 transactions for procurement and suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s procurement and suspension and debarment policies. Cause: The University experienced turnover during the year and documentation could not be located. Effect: Supporting documentation could not be located to support required procurement and suspension and debarment standards were followed. Repeat Finding: No. Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding.
2022 ? 004 ? Procurement and Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Assistance Listing Number: 84.425F Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: When procuring property and services under a Federal award, entities must follow the procurement standards outlined in 2 CFR 200.218 through 200.327. Included in these requirements, a 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. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, 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. Condition: The University has implemented formal, written policies and procedures to align with the requirements for procurement and suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 5 transactions for procurement and suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s procurement and suspension and debarment policies. Cause: The University experienced turnover during the year and documentation could not be located. Effect: Supporting documentation could not be located to support required procurement and suspension and debarment standards were followed. Repeat Finding: No. Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding.
Criteria: A non-federal entity is required to have certain written policies and procedure in compliance with Uniform Guidance and must comply with the procurement standards as described in 2 CFR 200.318 through 2 CFR 200.327. Specifically, the non-federal entity must comply with the following: • 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 services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. • If the non-Federal entity has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian tribe, the non-Federal entity must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. Condition: AIRS does not appear to have created written purchasing or procurement policies and procedures as required by 2 CFR 200.318(a). Since AIRS is an affiliate organization of the Ethiopian Community Development Council (ECDC), it appears that the relationship between AIRS and ECDC meets the “affiliate” requirement under 2 CFR 200.318 (c) (2). It does appear that AIRS has created written standards of conduct covering organizational conflicts of interest. Cause: Management has not created or maintained certain written policies and procedures as required under 2 CFR 200.318. Effect: AIRS is not in compliance with certain written policies and procedures as required under 2 CFR 200.318. Questioned Costs: None reported Repeat Finding from Prior Year: No Recommendation: Management and board should create written procurement policies and procedures and written standards of conduct covering organizational conflicts of interest that comply with the procurement standards as required under 2 CFR 200.317 through 2 CFR 200.327. Views of Responsible Officials: Management concurs with this audit finding.
Finding 2021-002: Material Weakness – Lack of Documentation on Sole Source Contracts and Verification of Vendors Federal grantor: Department of Commerce Condition: The Chamber contract with a vendor on a sole-source basis and did not document justification for the use of a sole source vendor. In addition, the Chamber did not verify that the vendor was not on the list of vendors suspended or debarred from federal contracting before contracting with the vendor. Criteria: Entities are required to follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320 and noncompetitive procurements. Entities also must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or voluntarily excluded from participating in Federal procurement. Cause: The Chamber’s Procurement Policy allows for a sole source vendor but requires staff to document sole source procurements prior to initial purchase. It appears staff did not follow its policy. The Policy also contains a requirement to verify or receive vendor certification that they are not debarred, suspended, ineligible or voluntarily excluded from Federal procurements, but this procedure was not followed. Effect: The Department of Commerce may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 C.F.C. section 200.339. Recommendation: We recommend the Chamber review policies with staff to ensure procurement requirements are followed, and that staff are familiar with federal procurement requirements. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
2 CFR § 1000.1 gives regulatory effect to the Department of Treasury for 2 CFR § 200.318 through 200.327 which describe specific procedures non-Federal entities must follow when entering into procurement transactions using Federal funds. 2 CFR § 200.318(a) indicates a non-Federal entity must have and use its own documented procurement procedures, consistent with State and local laws and regulations and the standards of 2 CFR § 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. 2 CFR § 200.320 indicates the non-Federal entity must use the following methods of procurement: (a) Procurement by micro-purchases, which the aggregate dollar amount does not exceed the non-Federal entity’s micro-purchase dollar threshold; (b) Procurement by small purchase procedures, which are procurements of relatively simple and informal nature, which do not exceed the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources; (c) Procurement by sealed bids, which requires public solicitation of bids and a firm fixed price contract (lump-sum or unit price) is awarded to the responsible bidder whose bid, conforming with all material terms and conditions in the invitations to bid, is the lowest in price; (d) Procurement by competitive proposals, which is generally used when conditions are not appropriate for the use of sealed bids and is a procurement method in which either a fixed price or cost-reimbursement type contract is awarded; or (e) Procurement by non-competitive proposals, which are appropriate when an item can be obtained only from a single source, the non-competitive procurement is specifically authorized by the Federal awarding agency or pass-through entity, competition is deemed adequate after solicitation through competitive means, the aggregate amount of procurement does not exceed the micro-purchase threshold, and/or the public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation. 2 CFR § 200.318(i) indicates 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. 31 CFR § 19.300 indicates before entering into a covered transaction as defined in 31 CFR § 19 Subpart B, the non-Federal entity must ensure the expenditure is not made to an individual or business that is excluded or disqualified from receiving Federal funds by checking the Excluded Party List System (EPLS), collecting a certification from the individual or business, or adding a clause or condition to the contract. The City did not establish the necessary controls or policies to ensure proper compliance with Procurement requirements. For five of five procurements in excess of the City’s micro-purchase threshold which were entered into using Coronavirus State and Local Fiscal Recovery Funds (SLRF), the City did not maintain records sufficient to detail the history of the procurement. It was not evident if the City obtained quotes or bids for the items purchased or if a cost-price analysis was performed. Additionally, the City did not have written procurement procedures that conform to applicable laws noted above. Finally, the City did not ensure the vendors paid under covered transactions using SLRF funds were not excluded or disqualified from receiving Federal funds. The City should review the procurement requirements contained in 2 CFR § 200.318 through 200.327 and develop policies and procedures to ensure compliance. The City should maintain sufficient documentation to detail the history of the procurement, which may vary depending on the procurement method used. As a part of the procurement process, the City should include procedures for ensuring a vendor is not excluded or disqualified from receiving Federal funds and maintain documentation the procedure was followed.
Criteria: A non-federal entity is required to have certain written policies and procedure in compliance with Uniform Guidance and must comply with the procurement standards as described in 2 CFR 200.318 through 2 CFR 200.327. Specifically, the non-federal entity must comply with the following: • 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 services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. • If the non-Federal entity has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian tribe, the non-Federal entity must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. Condition: AIRS does not appear to have created written purchasing or procurement policies and procedures as required by 2 CFR 200.318(a). Since AIRS is an affiliate organization of the Ethiopian Community Development Council (ECDC), it appears that the relationship between AIRS and ECDC meets the “affiliate” requirement under 2 CFR 200.318 (c) (2). It does appear that AIRS has created written standards of conduct covering organizational conflicts of interest. Cause: Management has not created or maintained certain written policies and procedures as required under 2 CFR 200.318. Effect: AIRS is not in compliance with certain written policies and procedures as required under 2 CFR 200.318. Questioned Costs: None reported Repeat Finding from Prior Year: No Recommendation: Management and board should create written procurement policies and procedures and written standards of conduct covering organizational conflicts of interest that comply with the procurement standards as required under 2 CFR 200.317 through 2 CFR 200.327. Views of Responsible Officials: Management concurs with this audit finding.
Finding 2021-002: Material Weakness – Lack of Documentation on Sole Source Contracts and Verification of Vendors Federal grantor: Department of Commerce Condition: The Chamber contract with a vendor on a sole-source basis and did not document justification for the use of a sole source vendor. In addition, the Chamber did not verify that the vendor was not on the list of vendors suspended or debarred from federal contracting before contracting with the vendor. Criteria: Entities are required to follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320 and noncompetitive procurements. Entities also must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or voluntarily excluded from participating in Federal procurement. Cause: The Chamber’s Procurement Policy allows for a sole source vendor but requires staff to document sole source procurements prior to initial purchase. It appears staff did not follow its policy. The Policy also contains a requirement to verify or receive vendor certification that they are not debarred, suspended, ineligible or voluntarily excluded from Federal procurements, but this procedure was not followed. Effect: The Department of Commerce may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 C.F.C. section 200.339. Recommendation: We recommend the Chamber review policies with staff to ensure procurement requirements are followed, and that staff are familiar with federal procurement requirements. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.
2 CFR § 1000.1 gives regulatory effect to the Department of Treasury for 2 CFR § 200.318 through 200.327 which describe specific procedures non-Federal entities must follow when entering into procurement transactions using Federal funds. 2 CFR § 200.318(a) indicates a non-Federal entity must have and use its own documented procurement procedures, consistent with State and local laws and regulations and the standards of 2 CFR § 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. 2 CFR § 200.320 indicates the non-Federal entity must use the following methods of procurement: (a) Procurement by micro-purchases, which the aggregate dollar amount does not exceed the non-Federal entity’s micro-purchase dollar threshold; (b) Procurement by small purchase procedures, which are procurements of relatively simple and informal nature, which do not exceed the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources; (c) Procurement by sealed bids, which requires public solicitation of bids and a firm fixed price contract (lump-sum or unit price) is awarded to the responsible bidder whose bid, conforming with all material terms and conditions in the invitations to bid, is the lowest in price; (d) Procurement by competitive proposals, which is generally used when conditions are not appropriate for the use of sealed bids and is a procurement method in which either a fixed price or cost-reimbursement type contract is awarded; or (e) Procurement by non-competitive proposals, which are appropriate when an item can be obtained only from a single source, the non-competitive procurement is specifically authorized by the Federal awarding agency or pass-through entity, competition is deemed adequate after solicitation through competitive means, the aggregate amount of procurement does not exceed the micro-purchase threshold, and/or the public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation. 2 CFR § 200.318(i) indicates 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. 31 CFR § 19.300 indicates before entering into a covered transaction as defined in 31 CFR § 19 Subpart B, the non-Federal entity must ensure the expenditure is not made to an individual or business that is excluded or disqualified from receiving Federal funds by checking the Excluded Party List System (EPLS), collecting a certification from the individual or business, or adding a clause or condition to the contract. The City did not establish the necessary controls or policies to ensure proper compliance with Procurement requirements. For five of five procurements in excess of the City’s micro-purchase threshold which were entered into using Coronavirus State and Local Fiscal Recovery Funds (SLRF), the City did not maintain records sufficient to detail the history of the procurement. It was not evident if the City obtained quotes or bids for the items purchased or if a cost-price analysis was performed. Additionally, the City did not have written procurement procedures that conform to applicable laws noted above. Finally, the City did not ensure the vendors paid under covered transactions using SLRF funds were not excluded or disqualified from receiving Federal funds. The City should review the procurement requirements contained in 2 CFR § 200.318 through 200.327 and develop policies and procedures to ensure compliance. The City should maintain sufficient documentation to detail the history of the procurement, which may vary depending on the procurement method used. As a part of the procurement process, the City should include procedures for ensuring a vendor is not excluded or disqualified from receiving Federal funds and maintain documentation the procedure was followed.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.