Finding Text
Federal Agency: United States Department of the Treasury
Federal Program Name: Coronavirus State and Local Recovery Funds
CFDA Number: 21.027
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Uniform Guidance section 200.318 states non-Federal entities must
maintain records sufficient to detail the history of procurements. These records will include, but are not
necessarily limited to the following: rationale for the method of procurement, selection of contract type,
contractor selection or rejection, and the basis for the contract price.
Condition: For the four construction pay applications selected for testing, we noted no written
documentation on the procurement selection method.
Context: Four out of four reimbursement requests/pay applications did not have proper documentation
of procurement.
Cause: There is no procurement policy in place.
Effect: Procuring vendors without full and open competition.
Repeat Finding: No.
Recommendation: We recommend the Organization adopt a procurement policy and retain evidence
of procurement in their files at the time it takes place. We also recommend the suspension and
debarment search be performed on the SAM.gov website and documentation is retained so as to
provide evidence that this check was performed.
Views of responsible officials and planned corrective actions: There is no disagreement with the
audit finding.