Finding Text
2023-003 Procurement Policy
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Transportation
Program: 20.205 Highway Planning and Construction
Award Number and Year: 1052063; 2023
Pass-Through Agency: Minnesota Department of Transportation
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Title 2 U.S. Code of Federal Regulations § 200.318 states that the non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation.
Condition: Traverse County has written procurement policies; however, these policies do not include the required components in accordance with Title 2 U.S. Code of Federal Regulations §200.318.
Questioned Costs: None
Context: This issue was discovered during the audit of the major federal program; however, it impacts federal programs entity-wide. Written policies that reflect the specific components of federal regulations improve controls to ensure compliance with federal award requirements.
Effect: Written policies and procedures that are not updated to reflect the federal procurement requirements could increase the risk of noncompliance with federal program requirements.
Cause: Traverse County management was unaware the procurement policy did not include all the requirements.
Recommendation: We recommend Traverse County include the specific components of the Uniform Guidance requirements in its written procurement policies and procedures.
View of Responsible Official: Acknowledge