Finding 1239871 (2024-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-10-02

AI Summary

  • Core Issue: The organization lacks adequate controls over federal procurement, leading to repeated findings of material weaknesses in compliance.
  • Impacted Requirements: Failure to document procurement methods, evaluate conflicts of interest, verify contractor eligibility, and monitor contractor performance violates federal procurement standards.
  • Recommended Follow-Up: Management should implement written federal procurement procedures and a standardized review process to ensure compliance and proper documentation for all federal awards.

Finding Text

2024-004 - Inadequate Controls Over Federal Procurement and Suspension and Debarment Finding Type: Material weakness in internal control over compliance. Repeat Finding: Yes; prior year finding 2023-003. Status: Repeated; corrective action was not fully implemented during the current audit period. Federal Award: 21.027 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Criteria: The Uniform Guidance requires non-Federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the awards are administered in compliance with applicable federal statutes, regulations, and award terms and conditions. The federal procurement standards require non-Federal entities to maintain documented procurement procedures and records sufficient to support the history of each procurement, including the procurement method used, contractor selection or rejection, and the basis for the contract price. The standards also require written conflict-of-interest provisions, appropriate oversight of contractor performance, and inclusion of applicable federal provisions in contracts. Additionally, suspension and debarment requirements prohibit covered transactions with parties that are debarred, suspended, or otherwise Criteria (continued): excluded from participation in federal programs. Eligibility must be verified through the System for Award Management, a contractor certification, or an appropriate clause or condition in the covered transaction. Condition/Finding: During the audit, we noted that the Organization had not established and implemented sufficient controls over procurements charged to the federal program. Specifically, the Organization could not provide sufficient documentation demonstrating that: • The rationale for the procurement method and contractor selection was documented; • Potential conflicts of interest were evaluated; • Applicable contractors were verified as not suspended, debarred, or otherwise excluded; • Required federal provisions were included in applicable contracts; and • Contractor performance and compliance with contract terms were appropriately monitored. Cause: The Organization’s existing purchasing policies and procedures did not incorporate the federal-specific requirements applicable to procurements charged to federal awards. As a result, the Organization had not established a standardized process to identify, perform, document, and retain evidence of the required federal procurement and suspension and debarment procedures. Effect: The absence of appropriately designed and implemented controls creates a reasonable possibility that material noncompliance with federal procurement and suspension and debarment requirements could occur and not be prevented, or detected and corrected, on a timely basis. This could result in unsupported procurement decisions, transactions with ineligible contractors, contracts that omit required federal provisions, or inadequate oversight of contractor performance. Questioned Costs: None. Recommendation: We recommend that management adopt written federal procurement procedures and implement a standardized review process for procurements charged to federal awards. The process should address and document the procurement method and contractor selection, potential conflicts of interest, contractor eligibility, required federal contract provisions, and oversight of contractor performance. Documentation should be retained with each procurement file and be subject to appropriate management review and approval. View of Responsible Officials (Corrective Action): See corrective action plan.

Corrective Action Plan

Finding: 2024-004 - Inadequate Controls Over Federal Procurement and Suspension and Debarment Finding Type: Material weakness in internal control over compliance. Repeat Finding: Yes; prior-year finding 2023-003. Federal Award: ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Auditor Description of Condition and Effect: During the audit, we noted that the Organization had not established and implemented sufficient controls over procurements charged to the federal program. The Organization could not provide sufficient documentation demonstrating that: • The rationale for the procurement method and contractor selection was documented; • Potential conflicts of interest were evaluated; • Applicable contractors were verified as not suspended, debarred, or otherwise excluded; • Required federal provisions were included in applicable contracts; and • Contractor performance and compliance with contract terms were appropriately monitored. The absence of appropriately designed and implemented controls creates a reasonable possibility that material noncompliance with federal procurement or suspension and debarment requirements could occur and not be prevented, or detected and corrected, on a timely basis. This could result in unsupported procurement decisions, transactions with excluded or otherwise ineligible contractors, contracts that omit required federal provisions, or inadequate oversight of contractor performance. Auditor Recommendation: Management should adopt written federal procurement procedures and implement a standardized review process for procurements charged to federal awards. The process should address and document the procurement method and contractor selection, potential conflicts of interest, contractor eligibility, required federal contract provisions, and oversight of contractor performance. Documentation should be retained with each procurement file and be subject to appropriate management review and approval. Management Response and Corrective Action Planned: The Organization agrees with the finding. Management will adopt written federal procurement procedures and use a standardized checklist for each procurement charged to a federal award. The checklist will document the procurement method, contractor selection and price basis, evaluation of potential conflicts of interest, contractor eligibility verification, applicable federal contract provisions, and contractor oversight. A designated management reviewer will approve the completed procurement file, and the supporting records will be retained in accordance with the applicable award requirements.

Categories

Procurement, Suspension & Debarment Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1239867 2024-003
    Material Weakness Repeat
  • 1239868 2024-003
    Material Weakness Repeat
  • 1239869 2024-003
    Material Weakness Repeat
  • 1239870 2024-003
    Material Weakness Repeat
  • 1239872 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $689,546
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $263,359
10.558 CHILD AND ADULT CARE FOOD PROGRAM $14,863