Finding Text
Reference Number: 2023-05 Finding: Finding Type: Significant Deficiency in Internal Control Over Compliance Title and ALN of Federal Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria or Specific Requirement: I. Procurement – 2 CFR sections 200.318 – 200.326 of the Uniform Guidance require that non-federal entities follow documented procurement procedures that ensure full and open competition. All purchases using federal funds must comply with applicable thresholds, documentation, and approval requirements. Additionally, Franklin County Department of Job and Family Services (the pass-through grantor) requires that subrecipient entities also follow procurement requirements identified. Condition: The Organization did not follow required procurement procedures for subrecipient transactions. Cause: Though a procurement policy exists for the Organization, there was no enforcement of this policy for the federal program. Effect or Potential effect: Failure to follow a formal procurement policy causes the Organization to be out of compliance with Uniform Guidance and/or grant requirements and increases the likelihood of disallowance of costs. Questioned costs: None Identification as a Repeat Finding: N/A – this was not reported as a finding in the prior audit report. Context: The Organization did not follow required procurement procedures under the major program as no competitive bidding or documented justification for sole sourcing was provided. Recommendation: We recommend that the Organization revisit their existing procurement policy and implement a formal process to flag new purchase transactions and ensure the policy is followed. Periodic reviews of procurement activity tied to federal awards should also take place. Views of Responsible Officials: Management agrees with the finding and recommendation.