Finding Text
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-through Agency: Northampton County Pass-Through Number: N/A Award Period: May 18, 2022 - December 31, 2025; October 1, 2022 - December 31, 2025 May 18, 2023 - December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: Uniform Guidance (2 CFR §§ 200.317–200.327) requires non‑federal entities to maintain written procurement procedures and documentation supporting procurement transactions to ensure compliance with applicable federal regulations. Additionally, entities must verify and document that vendors are not suspended or debarred from participation in federal programs prior to award, in accordance with 2 CFR § 200.214. Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Questioned Costs: None. Context: Procurement and suspension and debarment documentation was requested for audit testing, and management was unable to provide documentation supporting the procurement selections and vendor eligibility for the items tested. Cause: The Organization did not consistently maintain required procurement and suspension and debarment documentation. Contributing factors included turnover within the finance and administrative functions and the absence of formalized procedures to ensure documentation is retained and readily available for audit and monitoring purposes. Effect: The lack of procurement and suspension and debarment documentation constitutes noncompliance with federal procurement requirements. Without adequate documentation, the Organization cannot demonstrate that procurements were conducted in accordance with Uniform Guidance or that vendors were eligible to receive federal funds and increases the risk of improper or unsupported expenditures of federal funds. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award. Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.