Finding 1155836 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-10-07

AI Summary

  • Core Issue: Lack of documentation for price or rate quotations on small purchases over $10,000 led to noncompliance with procurement requirements.
  • Impacted Requirements: Must comply with 2 CFR section 200.320 regarding procurement methods for purchases between $10,000 and $250,000.
  • Recommended Follow-Up: Ensure all vendors maintain documentation for price quotations on potential purchases exceeding the micro-purchase threshold, not just those above $10,000.

Finding Text

Federal Agency: Department of the Interior Federal Program Name: Boston Harbor Islands Partnership - World's End Carriage Road Restoration Assistance Listing Number: 15.947 Federal Award Identification Number and Year: N/A Pass-Through Agency: National Park Service Pass-Through Number(s): P24AC02282 - 2023 Award Period: 10/01/2023 – 09/30/2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: Procurement methods used must be in compliance with conditions specified in 2 CFR section 200.320. Condition: For the acquisition of small purchases of which the aggregate dollar amount is higher than the micro-purchase threshold ($10,000) but does not exceed the simplified acquisition threshold ($250,000), price or rate quotations must be obtained from an adequate number of qualified sources. Questioned costs: None. Context: Documentation over price or rate quotations was not maintained for 2 (of 5) testing selections. Cause: Documentation over price or rate quotations was not maintained, which prohibited the auditors from successfully perform testing over these transactions. Effect: Noncompliance with Uniform Guidance procurement requirements. Repeat Finding: N/A. Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micro-purchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micropurchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Small Purchase Procurement: We have enhanced document retention procedures around small purchase procurement including staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure a minimum of 3 bids/quotes are obtained on any grant-funded purchases or services greater than $10k. We will be utilizing NetSuite's Document Library to manage document retention for grant-related bids and quotes. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1155837 2025-002
    Material Weakness Repeat
  • 1155838 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.947 Boston Harbor Islands Partnership $323,103
15.929 Save America's Treasures $252,791
45.149 Promotion of the Humanities Division of Preservation and Access $177,957
11.473 Office for Coastal Management $156,659
14.218 Community Development Block Grants/entitlement Grants $120,000
15.623 North American Wetlands Conservation Fund $28,625
45.025 Promotion of the Arts Partnership Agreements $27,280
10.912 Environmental Quality Incentives Program $15,527
45.301 Museums for America $13,822
66.456 National Estuary Program $3,849