Finding 1061592 (2023-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-08-27
Audit: 317961
Organization: Iron County, Wisconsin (WI)

AI Summary

  • Core Issue: The County failed to follow its own procurement policies, leading to non-compliance with federal requirements.
  • Impacted Requirements: This affects adherence to 2 CFR 200.320(a)(2)(ii), which mandates proper procurement thresholds and verification of vendor eligibility.
  • Recommended Follow-Up: The County should review and update its procurement policies to align with federal standards for all grants.

Finding Text

Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding • Significant Deficiency in Internal Control Over Compliance and Other Matters Criteria or Specific Requirement: 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County did not follow controls related to ensuring procurement policies were followed. Questioned Costs: None. Context: There were 18 transactions that exceeded procurement thresholds during the granting period. The sample size selected tested was 6. During our testing, it was noted on 4 of the 6 items tested that the County was not following the requirements under the adopted procurement policies. Cause: The County did not follow the requirements under the adopted procurement policies. Effect: The County is not in compliance with procurement requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding: Repeat finding of 2022-004. Recommendation: We recommend the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials: There is no disagreement with the finding.

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 485147 2023-003
    Significant Deficiency Repeat
  • 485148 2023-003
    Significant Deficiency Repeat
  • 485149 2023-003
    Significant Deficiency Repeat
  • 485150 2023-003
    Significant Deficiency Repeat
  • 485151 2023-004
    Significant Deficiency
  • 485152 2023-004
    Significant Deficiency
  • 485153 2023-004
    Significant Deficiency
  • 485154 2023-004
    Significant Deficiency
  • 485155 2023-004
    Significant Deficiency
  • 485156 2023-004
    Significant Deficiency
  • 485157 2023-004
    Significant Deficiency
  • 1061589 2023-003
    Significant Deficiency Repeat
  • 1061590 2023-003
    Significant Deficiency Repeat
  • 1061591 2023-003
    Significant Deficiency Repeat
  • 1061593 2023-004
    Significant Deficiency
  • 1061594 2023-004
    Significant Deficiency
  • 1061595 2023-004
    Significant Deficiency
  • 1061596 2023-004
    Significant Deficiency
  • 1061597 2023-004
    Significant Deficiency
  • 1061598 2023-004
    Significant Deficiency
  • 1061599 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $111,742
93.556 Promoting Safe and Stable Families $33,310
21.032 Local Assistance and Tribal Consistency Funds $30,581
97.042 Emergency Management Performance Grants $26,677
93.053 Nutrition Services Incentive Program $20,005
20.600 State and Community Highway Safety $16,683
93.069 Public Health Emergency Preparedness $16,293
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $14,793
93.235 Affordable Care Act (aca) Abstinence Education Program $14,295
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $13,419
84.181 Special Education-Grants for Infants and Families $12,356
93.052 National Family Caregiver Support, Title Iii, Part E $10,822
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $10,323
93.643 Children's Justice Grants to States $9,996
21.027 Coronavirus State and Local Fiscal Recovery Funds $9,852
93.658 Foster Care_title IV-E $8,305
93.324 State Health Insurance Assistance Program $7,000
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $5,791
93.994 Maternal and Child Health Services Block Grant to the States $4,580
93.568 Low-Income Home Energy Assistance $4,341
93.268 Immunization Cooperative Agreements $4,211
20.219 Recreational Trails Program $3,852
93.958 Block Grants for Community Mental Health Services $3,621
93.991 Preventive Health and Health Services Block Grant $3,370
93.959 Block Grants for Prevention and Treatment of Substance Abuse $3,300
93.217 Family Planning_services $3,293
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $2,995
93.659 Adoption Assistance $2,025
93.071 Medicare Enrollment Assistance Program $1,746
93.090 Guardianship Assistance $1,517
93.575 Child Care and Development Block Grant $1,376
93.667 Social Services Block Grant $1,357
93.767 Children's Health Insurance Program $1,179
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $1,137
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $980
93.645 Stephanie Tubbs Jones Child Welfare Services Program $509
93.563 Child Support Enforcement $77
93.747 Elder Abuse Prevention Interventions Program $60
93.558 Temporary Assistance for Needy Families $23