Finding Text
2024-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance. Criteria or Specific Requirement 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. Condition The County did not follow controls related to ensuring procurement procedures were followed. Questioned Costs None Context While performing compliance procedures, it was noted that the County did not follow adopted policies for procurement. Cause The County did not follow controls related to ensuring procurement procedures were followed. Effect The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction-related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2024-004 (Continued) Recommendation We recommend the County follow their procurement policy and maintaining this documentation. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.