Finding Text
Finding 2024-001 - Significant Deficiency: Procurement and Suspension and Debarment - Compliance and Control Finding ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Economic Development Fiscal Year End: For the year ended December 31, 2024 Criteria Or Specific Requirement: The Uniform Guidance requires the Foundation to adhere to federal procurement requirements when expending federal funds. The Foundation also must adhere to federal requirements to ensure that its contractors have not been suspended or debarred from receiving federal funds. Condition: The Foundation procured services with two vendors in an amount in excess of the $250,000 simplified acquisition threshold. Required procurement methods were not followed for these vendors. Additionally, the Foundation did not maintain documentation of their review that the contractors had not been suspended or debarred from receiving federal funds by either including appropriate language to this effect within the contract or maintaining documentation that the contractor was not included within the suspension and debarment listing within the EPLS database. Cause: The Foundation did not have a documented procurement policy in place to ensure that procurement and suspension and debarment procedures were followed and/or documented. Effect: The Foundation could contract with a contractor who is either not the most-qualified and/or lowest cost provider, or who is suspended or debarred. Context: The Foundation procured services with two vendors in an amount in excess of the $250,000 simplified acquisition threshold. A formal bidding process, including ensuring free and open competition, did not occur due to the establishment of these vendor relationships many years before of the awarding of this federal grant. In addition, the Foundation did not maintain documentation supporting their verification that the contractors were not suspended or debarred at the time the contract was executed. Review confirmed the contractors are not suspended or debarred. Questioned Costs: None noted. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document and follow a procurement policy in alignment with the Uniform Guidance requirements. Views Of Responsible Officials: The establishment of these vendor relationships occurred many years before the awarding of this federal grant. For future procurement transactions, the Foundation is aware of the additional Uniform Guidance requirements and will ensure compliance, if necessary.