Finding Text
Significant Deficiencies in Internal Control over Compliance 2025-005 – Procurement, Suspension and Debarment Program: Partners for Fish and Wildlife Federal Assistance Listing No: 15.631 Federal Agency: U.S. Department of Interior Federal Award Identification Number: F22AC02789-00/F21AC02494-00 Year: 2024 Criteria or Specific Requirement Uniform Guidance requires non-federal entities to maintain written procurement procedures that provide for full and open competition and comply with applicable federal, state, and local laws and regulations. In addition, 2 CFR §180 and §200.213 require non-federal entities to ensure that vendors receiving federal funds are not suspended or debarred, and to have procedures in place to verify vendor eligibility prior to contract award. Condition The Weed & Pest District does not have formal, written policies or procedures governing procurement activities, including required procurement methods, documentation standards, and approval thresholds. Additionally, the Weed & Pest District lacks documented procedures to verify and confirm that vendors are not suspended or debarred prior to entering into contracts or making payments with federal funds. Independently, we verified that the contractor was not suspended or debarred. Independently, we verified that the contractor was not suspended or debarred. Cause Weed and Pest District has not established formal procurement and suspension and debarment policies due to limited administrative resources and a reliance on informal practices rather than documented policies. Effect or Potential Effect Without formal procurement and suspension and debarment policies, Weed & Pest District faces an increased risk of noncompliance with federal regulations. This raises the likelihood of unallowable activities or questioned costs, reduced competition, procurement inefficiencies, and potential contracts with ineligible vendors. Continued noncompliance could result in required repayment of federal funds, or other sanctions from grantor agencies. Questioned Costs None identified. Context The Weed & Pest District did not have formal policies for procurement, suspension and debarment. Identification of a Repeat Finding No Recommendation We recommend that Weed and Pest District develop, adopt, and implement written procurement and suspension and debarment policies and procedures in accordance with Uniform Guidance. Alternatively, Weed and Pest District could consider adopting the County’s procurement and suspension and debarment policies. In addition, Weed and Pest District should establish processes and controls to ensure compliance with these policies. Views of Responsible Officials Management agrees with the finding and plans to develop and formally adopt procurement and suspension and debarment policies. Implementation is expected to occur during the next fiscal year.