Finding Text
Non-compliance with Federal Award Requirement Identification of Federal Program 20.205 - Highway Construction and Planning; U.S. Department of Transportation; Passed-through State of Mississippi Department of Transportation Criteria 2 CFR 200.318(a) requires non-Federal entities to maintain and use documented procurement procedures that are consistent with applicable Federal statutes, regulations, and the standards identified in 2 CFR 200.317 through 200.327 as well as maintaining written standards of conduct covering conflicts of interest and governing the actions of employees engaged in the selection, award, and administration of contracts supported by Federal funds. Condition For the year under audit, the City did not have documentation of adopted procurement policies and procedures that addressed procurement standards or a written standard of conduct governing employees engaged in contract administration as required by Uniform Guidance. Cause Management had not established or adopted formal policies and procedures to ensure compliance with the procurement requirements of Uniform Guidance. Effect Without documented procurement policies and written standards of conduct, the City is at increased risk of noncompliance with Federal procurement requirements. Questioned Costs No questioned costs resulted from this matter. Repeat Finding This is not a repeat finding. Recommendation We recommend management development, approve, and implement written procurement policies and procedures and adopt a written standard of conduct addressing conflicts of interest and ethical expectations for employees and officials involved in the procurement process. Views of Responsible Officials Managment contends they have followed state procurement law and has since adopted a formal policy stipulating compliance with State of Mississippi procurement and Federal procurement requirements. A written standard of conduct for employees engaged in contract selection, award, and administration is in process and expected to be formally adopted in the near future.