Finding Text
2023 – 006 Procurement Federal agency: U.S. Treasury Department Federal program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds FALN Number: 21.027 Federal Award Identification Number: CPAP000000381538 Award Period: March 2021 through December 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Condition: During our testing, we noted the County did not have internal controls designed to ensure compliance with federal procurement requirements. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. The County should have internal controls designed to ensure compliance with those provisions. The County is required to have documentation and follow procurement requirements including obtaining price or rate quotations from an adequate number of qualified sources for small purchases and sealed bids. Questioned costs: None Context: During our testing, it was noted that the County did not follow procurement requirements for 1 of 5 procurements (1 of 1 small purchases) tested. Additionally, the County does not have a policy to specifically adhere to federal grant requirements. Cause: The County does not have a written procurement policy in place that clearly addresses compliance with federal grant requirements per the Uniform Guidance. Effect: Internal controls over procurement were not adequately designed or implemented, increasing the risk that procurement decisions were inconsistent, inadequately documented, or not in compliance with federal requirements. Repeat finding: Yes, 2022-005 Recommendation: We recommend the County review the federal procurement requirements outlined in the federal Uniform Guidance and create a written policy to address federal compliance requirements. Additionally, we recommend a designated individual at the County ensures purchases made with federal grant funding comply with federal procurement requirements by type of procurement (micropurchase, small purchase, sole-source, etc.) and also suspension and debarment requirements. Views of responsible officials: The Menard County Treasurer will provide appropriate in-house training for federal procurement requirements as relayed in the Uniform Guidance. A written policy will be created and adhered to addressing federal compliance requirements with procurement requirements.