Finding Text
Department of the Treasury Federal Financial Assistance Listing/ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement policies required. Condition – The Organization does not have a procurement policy that conforms to applicable standards under Uniform Guidance and 2 CFR sections 200.318 through 200.326. In addition, it was noted that there was no documentation to support suspension and debarment verification. Additionally, the Organization did not have proper procedures to ensure contracts include all required provisions. Cause – The Organization did not have proper procedures to ensure a procurement policy in accordance with Uniform Guidance was followed and controls were not adequately designed to ensure compliance with all the requirements for procurement, suspension, and debarment. Effect – The Organization did not comply with Uniform Guidance relating to Procurement. Questioned Costs – None reported. Context/Sampling – Overall procurement policy and two contracts out of a population of six total contracts. Repeat Finding from Prior Year(s) – No Recommendation – We recommend the Organization revise their procurement policy to follow Uniform Guidance and to follow those applicable procurement policies for applicable contracts. We also recommend the Organization review all contracts to ensure they include all required provisions as outlined by Uniform Guidance. Views of Responsible Officials – There is no disagreement with the finding.