Finding Text
CFDA No. 14.228 – Community Development Block Grant
Year Ended – May 31, 2024
Passed Through the NEW York State Housing Trust Fund
Federal Agency – U.S. Department of Housing and Urban Development
Criteria – the Village’s procurement policy must incorporate federal award activity within the process and procedures followed by the Village in accordance with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), sections 200.112, 200.317-200.326. Under the Uniform Guidance, the procurement requirements were required to be implemented by January 1, 2018 for federal award recipients.
Condition – The Village’s code of ethics, conflict of interest and procurement policies have not been updated to comply with the requirements in the Uniform Guidance.
Cause – The control environment related to the requirements of the Uniform Guidance has not be reviewed and incorporated into the Village’s control activities through the updating and documentation of the Village’s policies noted above.
Effect – The Village was not in compliance with the requirements of the Uniform Guidance, Section 200.112, Conflict of Interest and Sections 200.317-200.326, Procurement Standards.
Questioned Costs – There were no questioned costs noted related to this finding.
Context – This finding was identified during inquiries of management in regards to the control environment over the requirements of the Uniform Guidance and through the review of the related policies noted above.
Recommendation – We recommend the Village review their policies and establish/update such policies to ensure compliance with the Uniform Guidance.
Village’s Response – The Village Mayor will continue working with the consultants to update the required policies and procedures to ensure compliance during this next year.