Finding Text
Item:
2023-004
Assistance Listing Number:
21.027
Programs:
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Federal Agency:
U.S. Department of the Treasury
Pass-Through Agencies:
Arizona State Office of the Governor; Maricopa County
Pass-Through Grantor Identifying Number:
Unknown
Award Year:
January 1, 2022 to December 31, 2024; January 28, 2022 to June 30, 2023
Compliance Requirement:
Procurement, suspension and debarment
Criteria:
In accordance with 2 CFR § 200.318 - General procurement standards - the entity must use its own documented procurement procedures which reflect applicable. State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR § 200.318.
Condition:
The entity’s procurement policy and related procedures do not address the provisions of 2 CFR § 200.318
Questioned Costs:
n/a
Context:
In a population of over 250 procurements for program costs, we conducted a non-statistical sample of 40 transactions. In our sample of 40 transactions, it was noted that 39 procurements were below the micro-purchase threshold, and 1 procurement was above the micro-purchase threshold but below the small purchase threshold. We noted there was a procurement policy in place however, it was not written in compliance with 2 CFR § 200.318. Additionally, there was a lack of documentation retained by the organization to support procurement transactions. As such, this is deemed to be a material weakness in internal control over compliance.
Effect:
Undocumented procurement decisions could violate the requirements of 2 CFR § 200.318
Cause:
Special Olympics Arizona, Inc. did have a written procurement policy however, it did not conform to 2 CFR § 200.318. Additionally, Special Olympics Arizona, Inc. did not implement controls to ensure adherence to policies that conform to 2 CFR § 200.318.
Identification as a Repeat Finding:
Repeat finding of 2022-04
Recommendation:
The entity should prepare written procurement policies and implement controls to ensure adherence to the policies that conform to 2 CFR § 200.318.
Views of Responsible Officials:
Management of the Organization concurs with the finding. See Corrective Action Plan.