Finding Text
Department of the Treasury, Passed through the State of Michigan
Federal Financial Assistance Listing 21.029, CPFFN0190, 2024
COVID-19 – Coronavirus Capital Projects Fund
Procurement, Suspension, and Debarment
Material Weakness in Internal Control Over Compliance
Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards
non-federal entities other than states must follow when operating federal programs and the procurement
procedures required.
Condition – In our testing of procurement, suspension, and debarment it was identified that the Cooperative’s
written policy did not address the requirements of 2 CFR sections 200.318 through 200.326.
Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform
Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all
of these requirements.
Effect – A lack of compliant policies increases the overall risk of non-compliance.
Questioned Costs – None reported.
Context/Sampling – Overall procurement policy.
Repeat Finding from Prior Years – No.
Recommendation – We recommend that management establish a written policy that is in compliance with all of
the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326
and maintain adequate supporting documentation and records to document history and methods of
procurement and the procedures performed to comply with these CFR sections.
Views of Responsible Officials – There is no disagreement with the audit finding.