Finding 1229719 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-14
Audit: 410914
Organization: Town of Smithfield (RI)

AI Summary

  • Core Issue: The Town of Smithfield lacks a written conflict of interest policy for contract management, violating procurement standards.
  • Impacted Requirements: This deficiency relates to Uniform Guidance §200.318, which mandates written standards of conduct for procurement activities.
  • Recommended Follow-Up: The Town should develop and implement a conflict of interest policy to ensure compliance with federal procurement regulations.

Finding Text

Procurement Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus Capital Projects Fund (CCPF) Assistance Listing Number: 21.029 Federal Award Identification Number and Year: NOW-20005 - 2025 Pass-Through Agency: Rhode Island Department of the Treasury Pass-Through Number: NOW-20005 Award Period: August 2, 2023 – October 30, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Repeat Finding: No Criteria or specific requirement: Per Uniform Guidance §200.318 General procurement standards, a non-Federal entity must 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 Town of Smithfield does not have a written conflict of interest policy in place for the selection, award, and administration of contracts as required by Uniform Guidance. Questioned Costs: None Context: Although the Town does not have a written conflict of interest policy in place for the selection, award, and administration of contracts, we did not identify transactions where contracts were awarded where there appeared to be a conflict of interest in the procurement process in 3 of 3 procurement transactions tested. Cause: Management was not aware of the procurement standards set out at 2 CFR section §200.318 within Uniform Guidance. Effect: The Town is at risk for noncompliance with Federal grants as it relates to procurement. Recommendation: We recommend the Town implement a written conflict of interest policy in line with Uniform Guidance §200.318. Views of Responsible Officials: Management agrees with this finding.

Corrective Action Plan

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town does not have a written conflict of interest policy in place as required by Uniform Guidance §200.318 procurement standards. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management will establish written conflict of interest policies to ensure the Town is in compliance with procurement requirements of Uniform Guidance. Name of Contact Person Caitlyn Choiniere, Finance Director Projected Completion Date 7/1/2026

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 1229720 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $2.02M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.45M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $936,918
84.027 SPECIAL EDUCATION GRANTS TO STATES $739,647
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $591,382
10.555 NATIONAL SCHOOL LUNCH PROGRAM $330,105
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $148,872
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $133,100
16.068 COPS HIRING PROGRAM $125,000
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $115,462
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $89,727
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $76,283
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $63,782
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $63,465
10.553 SCHOOL BREAKFAST PROGRAM $50,697
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $37,212
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $33,651
84.425 EDUCATION STABILIZATION FUND $25,160
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $14,708
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $13,268
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $10,098
20.602 OCCUPANT PROTECTION INCENTIVE GRANTS $2,040
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $1,911
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $913