Finding 1055132 (2023-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-07-17
Audit: 315329
Organization: Effingham County (IL)

AI Summary

  • Core Issue: The County has a material weakness in internal controls over compliance related to procurement processes.
  • Impacted Requirements: Failure to maintain adequate documentation for procurement history and to verify vendor eligibility as required by Uniform Grant Guidance (2 CFR 200.318).
  • Recommended Follow-Up: Implement comprehensive procurement procedures, including a Federal Procurement Checklist, to ensure compliance and proper documentation for all federal purchases.

Finding Text

Federal Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Pass-Through Agency : N/A Pass-Through Number(s) : N/A Award Period: March 3, 2021 – December 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-federal entity to maintain records sufficient to detail the history of procurement. Additionally, federal guidelines require the entity to have procedures documented to verify the vendor of a covered transaction (over $25,000) is not debarred, suspended, or otherwise excluded from participating in the transaction, prior to entering into a covered transaction. Condition: Certain purchases were not adequately documented supporting the lack of traditional procurement processes being required. Additionally, the County did not complete suspension and debarment procedures for covered transactions. Questioned costs : None. Context : In the testing of 4 of 7 procurement transactions, the County did not maintain appropriate documentation to support the history of procurement, which should include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, in the testing of 5 of 5 covered transactions, the County did not complete the required suspension and debarment procedures prior to purchase. Cause: Timing of implementation of new controls occurred after some transactions had already been procured. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding : This is a repeat of prior year finding 2022-006. Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and available for all departments. These procedures should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting with them, and maintaining documentation of this. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 478690 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.30M
93.268 Immunization Cooperative Agreements $208,989
20.509 Formula Grants for Rural Areas and Tribal Transit Program $94,512
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $70,976
93.498 Provider Relief Fund $59,062
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $37,712
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $34,479
93.069 Public Health Emergency Preparedness $22,745
97.042 Emergency Management Performance Grants $22,396
20.106 Airport Improvement Program $14,406
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $11,400
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $7,988
93.667 Social Services Block Grant $5,176
16.922 Equitable Sharing Program $390
66.605 Performance Partnership Grants $200