Finding Text
Criteria: Per Federal regulations for general procurement standards (2 CFR § 200.318 (i)), non‑Federal entities must maintain records sufficient to detail the history of the procurement process. These records will include but are not limited to the following: rationale for the method of procurement, selection or rejection, and the basis for the contract price. Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for the projects selected. Cause and Effect: Due to the City not conducting procurement for all CSLFRF expenditures through its projects, sufficient evidence was not available to demonstrate that full and open competition was provided to potential bidders, as required. Documentation supporting compliance with procurement requirements, including public notice and solicitation efforts, was not available. Recommendation: We recommend the City implement and enforce procurement policies that require formal solicitation of bids for applicable projects. Initiating a competitive bidding process helps ensure compliance with federal and state procurement standards, promotes transparency, and supports the selection of the most qualified and cost‑effective vendors. Management Response: Management concurs with the finding that procurement documentation for CSLFRF‑funded projects was insufficient to demonstrate compliance with federal procurement standards, including the requirement for public notice under 2 CFR § 200.320(b). The absence of complete records limited the City’s ability to show that full and open competition was provided. To address this issue, the City will revise and strengthen its procurement policies to require formal solicitation and complete documentation for all applicable projects. A centralized system for retaining procurement records will be implemented to ensure that evidence of public notice, solicitation efforts, bid evaluations, and contract award decisions is consistently maintained. Staff involved in procurement will receive training on federal requirements, and a pre‑award compliance checklist will be introduced to verify that all required documentation is in place before contracts are executed. Management will work with all departments involved in procurement to reinforce expectations, implement improved procedures, and ensure that required documentation is consistently retained.