Finding Text
Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 395-0096-25-21 & 395-0096-25-22 – Year Ended December 31, 2025 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: § 200.318 “General procurement standards” states that recipients or subrecipients must maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The recipient or subrecipient must also maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. Condition: The Commission had not established written procurement or conflict of interest policies. Questioned costs: None Context: Although the Commission followed procurement, suspension and debarment processes to verify vendors met compliance requirements, no documented process or policies were maintained by the Commission. Cause: The lack of written policy and internal control structure does not include a process for ensuring procurement, suspension and debarment requirements are met for all required vendors. Effect: The Commission may contract with or make subawards under covered transactions that do not follow proper procurement processes or to parties that are suspended or debarred. Repeat Finding: No Recommendation: We recommend that the Commission update their current procurement and conflict of interest policies and implement a system of internal controls over procurement, suspension and debarment that will ensure compliance. Views of responsible officials: Management agrees with the finding.