Finding 1190909 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-27

AI Summary

  • Core Issue: Procurement policies did not fully comply with federal laws, risking inappropriate contracting.
  • Impacted Requirements: Failure to verify if entities are suspended or debarred before transactions, violating federal procurement standards.
  • Recommended Follow-up: Update procurement policies to include federal criteria and strengthen internal controls for compliance verification.

Finding Text

2025-004: U.S. Department of the Interior Direct and Pass-through Tahoe Resource Conservation District Southern Nevada Public Land Management, 15.235 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 15.235 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a recipient use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the policies conform to applicable federal law. In addition, recipients are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement policies were consistent with state laws under Nevada Revised Statutes but did not consider or conform to all applicable federal procurement laws. In addition, procedures were not followed to verify if an entity was suspended or debarred before entering into a covered transaction. Cause: North Lake Tahoe Fire Protection District (the District) did not have adequate internal controls to ensure procurement policies complied with applicable federal laws or to ensure procedures were followed to verify an entity was not suspended or debarred prior to entering into a covered transaction. Effect: An inappropriate procurement method may be used. A covered transaction may be entered into with an entity that is suspended or debarred. Questioned Costs: None Context/Sampling: All procurements were tested as a population of one was noted. Suspension and debarment verification procedures were not performed for the vendor. Lastly, as noted the procurement policies were reviewed and were absent consideration of federal criteria regarding: • Avoidance of acquisition of duplicative items • Awarding to responsible parties and contract oversight • Federal solicitation provisions • Disadvantaged Business Enterprise programs • Contract price and types • Bonding requirements • Contract provisions and recovered materials Repeat Finding from Prior Year: No Recommendation: We recommend the District update its written procurement policy to include federal laws and implement internal controls to ensure procedures are followed to verify an entity is not suspended or debarred prior to entering into a covered transaction. Views of Responsible Officials: North Lake Tahoe Fire Protection District agrees with this finding.

Corrective Action Plan

We acknowledge the critical importance of establishing and maintaining an effective system of internal control over compliance, including procurement, suspension, and debarment per Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) related to the assistance listing 15.235. As such, we are committed to taking immediate corrective actions to address documented procurement procedures to reflect applicable state and local laws and regulations and to ensure that our District (as a non-federal entity) is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. We have outlined below the specific steps we have already undertaken and will undertake: 1.Revise & Update Procurement Procedures: a.We conducted a comprehensive review of current procurement procedures to identify gaps. b.We have ensured procurement procedures address compliance with state and local laws and regulations. c.We have implemented an approval process to review and validate any new procedures before they are finalized. d.We have updated our procurement policies to reflect the specific requirements under 2 CFR Part 200, including provisions related to debarment and suspension. The policy will be approved by our Board of Directors at a public meeting, no later than June 30, 2026. 2.Staff Training & Capacity Building: a.We have assigned dedicated staff with clear roles and responsibilities to manage and comply with grant requirements, including application, compliance, and reporting, ensuring that all parties understand their obligations and deadlines. b.We will provide training for relevant staff on updated procedures, including specific training on 2 CFR Part 200 for procurement standards, and suspension/debarment requirements. c.Provide regular refresher training to ensure ongoing compliance and awareness of updates to federal, state, and local laws. 3.Strengthen Internal Monitoring and Oversight Mechanisms: a.Implement periodic audits of procurement and subaward transactions to ensure compliance with updated policies and procedures. b.Assign a compliance officer to monitor the effectiveness of the suspension and debarment verification process. c.Develop a reporting system for non-compliance or procurement violations, and establish a corrective action protocol to address any identified issues d.Regularly review compliance metrics and audit reports with senior management. By implementing these corrective actions, we are committed to addressing the material weakness in internal control over compliance, including procurement, suspension, and debarment. These steps will enhance the accuracy, reliability, and transparency of our financial reporting and improve our internal controls over our financial reporting. Responsible Parties and Accountability to be designated: 1.Jackie Dunklee CFO, Jed Horan, Assistant Fire Chief, and Isaac Pawning, Division Chief: Responsible for overseeing the update of procurement procedures and ensuring compliance with state, local, and federal regulations. 2.Erick, Rodriguez, Compliance Officer: Responsible for monitoring suspension and debarment verification, conducting audits, and overseeing staff training. 3.Procurement Staff: Responsible for implementing updated procedures and ensuring all contractors and subawardees are verified for suspension or debarment status. 4.Thelesa Montoya, Neves, Grant Administrator: Responsible for ensuring that federal grant expenditures comply with applicable procurement regulations and internal controls. Anticipated Completion Date: June 2026

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1190906 2025-003
    Material Weakness Repeat
  • 1190907 2025-004
    Material Weakness Repeat
  • 1190908 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.235 SOUTHERN NEVADA PUBLIC LAND MANAGEMENT $270,286