Finding 1155889 (2024-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2025-09-29

AI Summary

  • Core Issue: The Organization lacks written procurement policies, leading to noncompliance with federal standards.
  • Impacted Requirements: Failure to follow 2 CFR §200.318 and 2 CFR §200.320(a)(1) increases risks of inconsistent practices and misuse of funds.
  • Recommended Follow-Up: Develop and implement documented procurement policies, ensuring staff are trained and practices are aligned with federal regulations.

Finding Text

Finding: Item 2024-001 – General Procurement Standards Material Weakness Federal Program – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number – 21.027 Federal Award Number – PJ1350-ARP35-CMF 20220466 and 2159FR0357 Federal Agency – U.S. Department of the Treasury Pass-Through Entities – Board of County Commissioners of Tulsa County and City of Tulsa Criteria: Per 2 CFR §200.318(a), non-Federal entities must use documented procurement procedures consistent with applicable laws and regulations, and the standards set forth in the Uniform Guidance. Condition/context: The Organization did not have written procurement policies in place during the audit period. The Organization has an informal procurement process. We tested the two vendors for which expenditures exceeded the micro-purchases limit, as defined by 2 CFR §200.320(a)(1). For one of the vendors, expenditures totaled $52,477, and there was no documentation that price or rate quotations were obtained from an adequate number of qualified sources. Cause: The Organization had not developed or adopted written procurement policies. Effect: Without written procurement policies, there is an increased risk of noncompliance with Federal procurement standards, inconsistent procurement practices, and potential misuse of federal funds. Questioned cost: $52,477 Repeat finding: This is not a repeat finding. Recommendation: We recommend the Organization develop and implement written procurement policies that comply with 2 CFR §200.318, 2 CFR §200.318(c) and other applicable procurement standards. These policies should be communicated to relevant staff and incorporated into procurement practices. View of responsible officials: Management's response is reported in "Corrective Action Plan" at the end of this report.

Corrective Action Plan

Audit Finding Item 2024-001 Corrective Action Taken: In response to this finding, Tulsa Cares is developing and will formally adopt written procurement policies and procedures in alignment with the requirements outlined in 2 CFR 200.318(a). These policies will establish standards of conduct, ensure full and open competition, and provide clear guidance for the procurement of goods and services under federal awards. This corrective action will be completed by the next board meeting, scheduled for December 4, 2025. Responsible Party: Natalie Jarred, Chief Financial and Administrative Officer, is responsible for monitoring compliance with procurement policies and updating them as necessary.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1155890 2024-002
    Material Weakness Repeat
  • 1155891 2024-002
    Material Weakness Repeat
  • 1155892 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.241 Housing Opportunities for Persons with Aids $694,828
93.917 Hiv Care Formula Grants $469,313
93.136 Injury Prevention and Control Research and State and Community Based Programs $322,185
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $99,478
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges $48,321
97.024 Emergency Food and Shelter National Board Program $10,914
21.027 Coronavirus State and Local Fiscal Recovery Funds $84