Finding Text
Item: 2024-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Federal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: State of Arizona, Office of the Governor Pass-Through Grantor Identifying Number: Unknown Award Year: March 1, 2022 to September 30, 2024 Compliance Requirement: Procurement, suspension and debarment Criteria or Specific Requirement: In accordance with 2 CFR § 200.318 – Procurement Standards, the Association is required to maintain records to sufficiently detail the history of each procurement transaction, including the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The Association did not retain documentation regarding the procurement procedures over one of the vendors tested. Questioned Costs: N/A Context: In a population of 172 program costs, we conducted a non-statistical sample of 18 transactions. In our sample of 18 transactions, one procurement was above the micro-purchase but below the small purchase threshold for which there was no documentation retained regarding quotes or rates obtained from other vendors. Per review of all program costs, the untested costs either fell below the micro-purchase threshold or were explicitly named in the approved budget. Additionally, the Association has a written procurement policy that aligns with the requirements of 2 CFR § 200.318. As such this is deemed to be a significant deficiency in internal controls over compliance. Cause: The Association did not follow its procurement policy when purchasing goods and services under the federal award. Effect: Undocumented procurement decisions could violate the requirements of 2 CFR § 200.318. Repeat Finding: Repeat finding – prior year 2023-003 Recommendation: We recommend implementing stronger controls to ensure adherence to the policies that conform to 2 CFR § 200.318. Views of Responsible Officials and Planned Corrective Actions: Management of the Association concurs with the finding. See Corrective Action Plan.