Finding 1240384 (2023-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-10-13
Audit: 414877
Organization: UPPER PROVIDENCE TOWNSHIP (PA)

AI Summary

  • Core Issue: The organization lacks written policies and procedures for procurement, conflicts of interest, and suspension and debarment, which are required by federal guidelines.
  • Impacted Requirements: Compliance with 2 CFR Part 200 is at risk, increasing the chance of noncompliance with federal procurement standards.
  • Recommended Follow-Up: Management should create and implement formal policies addressing these areas to ensure compliance and mitigate risks.

Finding Text

Federal Agency: U.S. Department of the Treasury Federal Program: American Rescue Plan Act/Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: FAIN – SLFRP2608 and 2021 Pass-Through Agency: Pennsylvania Department of Community and Economic Development Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 to December 31, 2024 Finding Type: Significant Deficiency in Internal Control over Compliance and Noncompliance- Procurement, Conflict of Interest, Suspension and Debarment Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires recipients of federal awards to maintain written policies and procedures governing procurement activities, conflicts of interest, and suspension and debarment requirements. Internal controls should be designed and implemented to provide reasonable assurance that the entity complies with these requirements. Condition : During our audit, we noted the Organization had not established and documented written policies and procedures addressing procurement, conflicts of interest, suspension, and debarment in accordance with Uniform Guidance requirements. Context : Based on our testing of procurement, conflict of interest, and suspension and debarment compliance requirements, we determined that formal written policies and procedures covering these areas were not in place during the audit period. Cause : Management had not developed and formally adopted policies and procedures to address procurement, conflict of interest, suspension, and debarment requirements as prescribed by Uniform Guidance. Effect or Potential Effect : The absence of documented policies and procedures increases the risk that the Organization may not consistently comply with applicable federal procurement requirements, conflict of interest standards, and suspension and debarment provisions. This control deficiency creates an opportunity for noncompliance to occur and remain undetected in a timely manner. Questioned Costs: None identified. Repeat Finding: No. Recommendation : We recommend management formally develop, document, and implement written policies and procedures governing procurement, conflicts of interest, and suspension and debarment activities. Policies should include procedures for evaluating contractors and vendors, documenting conflict of interest considerations, and verifying suspension and debarment status in accordance with Uniform Guidance requirements. Views of Responsible Officials and Corrective Action Plan: There is no disagreement with the audit finding. Management understands the importance of written policies and procedures to ensure compliance with grants. The Township will develop and adopt the noted policies and procedures to ensure that the Township will comply going forward.

Corrective Action Plan

SIGNIFICANT DEFICIENCY US Department of Treasury 2023-002 American Rescue Pan Act/Coronavirus State and Local Fiscal Recovery Funds (ARPA) – Assistance Listing No. 21.027 Recommendation: We recommend management formally develop, document, and implement written policies and procedures governing procurement, conflicts of interest, and suspension and debarment activities. Policies should include procedures for evaluating contractors and vendors, documenting conflict of interest considerations, and verifying suspension and debarment status in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management understands the importance of written policies and procedures to ensure compliance with grants. The Township developed and adopted the noted policies and procedures to ensure that the Township will comply going forward. Name(s) of the contact person(s) responsible for corrective action: Timothy Tieperman, Township Manager Planned completion date for corrective action plan: June 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1240385 2023-003
    Material Weakness Repeat
  • 1240386 2023-004
    Material Weakness Repeat
  • 1240387 2023-005
    Material Weakness Repeat
  • 1240388 2023-004
    Material Weakness Repeat
  • 1240389 2023-005
    Material Weakness Repeat
  • 1240390 2023-004
    Material Weakness Repeat
  • 1240391 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.91M
97.029 FLOOD MITIGATION ASSISTANCE $226,323
97.039 HAZARD MITIGATION GRANT $144,713