Finding 1217653 (2023-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-06-16

AI Summary

  • Core Issue: Outdated procurement policies fail to meet current Uniform Guidance requirements for micro-purchases.
  • Impacted Requirements: Lack of formal processes for documenting price reasonableness and verifying vendor eligibility.
  • Recommended Follow-Up: Update procurement policies and establish documentation processes for price reasonableness and vendor checks.

Finding Text

The organization primarily utilizes micro-purchases; however: • Procurement policies are outdated and do not reflect current Uniform Guidance requirements, including micro-purchase standards • No formal process exists to document price reasonableness for micro-purchases • No documented process exists to verify vendors are not suspended or debarred (e.g., SAM.gov) • No evidence of vendor distribution practices (e.g., rotation or comparison) was maintained

Corrective Action Plan

LARS has updated its procurement policies and procedures to reflect current 2 CFR Part 200 requirements, including the following: • The updated policy defines micro-purchase thresholds in accordance with current Uniform Guidance standards and requires that micro-purchases be distributed equitably among qualified vendors to the extent practicable • A simple price reasonableness documentation requirement has been added for micro-purchases, requiring staff to note the basis for determining a cost is reasonable (e.g., comparison to a prior invoice, market price check, or vendor quote) • A SAM.gov vendor verification step has been incorporated into the procurement process. Staff are required to check SAM.gov prior to making a purchase from a new vendor and to document the result. Verification results are retained in the procurement file

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1217652 2023-006
    Material Weakness Repeat
  • 1217654 2023-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $574,563
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $416,705
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $186,172
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $181,311
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $89,614