Finding Text
2024-001 PROCUREMENT, SUSPENSION AND DEBARMENT
Grantor: U. S. Department of the Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
CFDA Number: 21.027
Pass-through Entities: CT Department of Social Services CT Department of Children and Families
CT Office of Early Childhood
CT Office of Victim Services
Criteria: When procuring property and services, entities must follow the procurement standards set out at 2 CFR sections 200.318-200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform applicable federal statutes and the procurement requirements identified in 2 CFR part 200.
Condition: The procurement policy in place during fiscal 2024 had not been updated to comply with the requirement of the Uniform Guidance as stated above, and did not specify a micro-purchase or small purchase threshold above which written quotes would be required. A formal written policy for ensuring vendors are not suspended or debarred was not included in the existing policy and therefore this process was not being executed in a consistent manner.
Questioned Costs:
None.
Effect: Certain purchases could be incurred at higher amounts than might have been the case had multiple written quotes been obtained prior to the transaction. However, all purchases tested appeared to be in the normal course of business and costs appeared reasonable. Our testing did not result in any questioned costs. Additionally, the potential existed that a vendor that could either be suspended or debarred could have unknowingly been utilized due to the existing process.
Cause: The agency did not timely complete the process to update its policies and procedures to conform with the Uniform Guidance by the expiration of the extended implementation deadline cited in the Uniform Guidance. A new policy was implemented subsequent to year-end.
Recommendation:
Additional training of relevant staff regarding the new policies and procedures should be considered, especially regarding retention of adequate documentation of bids, quotes, or other procedures including documentation of the checking of vendors against the suspension and debarment lists.
Views of Responsible Officials:
A new procurement policy, including a process to ensure vendors are not suspended or debarred, was prepared and implemented effective in January 2025. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed.