Finding Text
US Department of Transportation
Program Name: Federal Transit Cluster
AL# 20.507; 20.526
Significant Deficiency
Nonmaterial Non-Compliance
Finding: 2024-003
Criteria: In accordance 49 USC 5325(b)(1), the agency administering this program is responsible for
retention of documentation to support procurements. Management must monitor activities under federal
awards to assure compliance with federal requirements.
Condition: The Authority implemented procurement policies that conform with the Federal Uniform
Guidance. However, the Authority’s internal controls over procurement were not functioning as
intended.
Context: During our testing, we examined four procurements and one did not follow the Authority’s
policy. Expenditures were approved prior to payment; however, proper procurement documentation
was not kept on file as required by federal and Authority’s policy.
Effect: Purchases may be made without the proper procurement approvals.
Cause: Due to staff turnover at the Authority in recent years, there was an instance where proper
procurement documentation was not on file.
Questioned Costs: In accordance with 2 CFR 200, auditors are required to report known questioned
costs when likely questions costs are greater than $25,000. Known question costs are $13,421.
Recommendation: The Authority should have a system in place to ensure that the procurement policies
are implemented and functioning as intended.
Name of Contact Person: Scott Cook, Interim Finance Officer
Views of Responsible Officials and Planned Corrective Action: Management concurs with this
finding. Please refer to the Corrective Action Plan.