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.