Finding 13008 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The Commission lacks adequate internal controls to identify and document noncompetitive procurements as sole source acquisitions.
  • Impacted Requirements: Compliance with 2 CFR Part 200, specifically regarding procurement documentation and justification for noncompetitive contracts.
  • Recommended Follow-Up: Implement controls to ensure proper documentation is maintained for sole source justifications to prevent potential noncompliance.

Finding Text

Federal Agency: U.S. Department of Energy, Bonneville Power Administration Federal Program Name: Columbia Basin Pit Tag Assistance Listing Number: 81.999 Federal Award Identification Number and Year: 00078040 REL 35 ? 2021-2022 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, per ?200.320(c), noncompetitive procurements can only be used if one of five specific circumstances are met. Documentation for that assessment must be kept. The Commission should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure noncompetitive procurements were appropriately identified as sole source procurements. Questioned costs: $134,084 Context: In a statistically valid sample, two of seven procurement selections tested, representing 50% of the noncompetitive procurements tested, did not have sufficient documentation to appropriately determine that the procurements qualified as sole source acquisitions. Upon further review of the procurements in question, they did appear to merit the use of sole source procurement, however incomplete documentation was kept to identify the procurements as such. Cause: The selections in questions were for renewals of software agreements. Sole source justification may have been completed on the initial contracts and purchases, however these documents were either not retained or were inaccessible during the audit. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat Finding: No Recommendation: We recommend the Commission design controls to ensure adequate documentation is maintained to support sole source justifications. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Bonneville Power Administration: Columbia Basin Pit Tag ? Assistance Listing No. 81.999 Recommendation: CLA recommends the Commission design controls to ensure adequate documentation is maintained to support sole source justifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission completed sole source justification forms following this finding being brought to attention by the auditors. The plan for fiscal year 2023 is to review all sole source vendors to ensure there is a current and approved sole source justification form on file. Name(s) of the contact person(s) responsible for corrective action: Kathy Ameral and Michael Arredondo Planned completion date for corrective action plan: June 30, 2023

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 13009 2022-002
    Significant Deficiency
  • 589450 2022-001
    Significant Deficiency
  • 589451 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.454 Covid 19 - Unallied Management Projects $100.88M
11.477 Fisheries Disaster Relief $31.57M
11.437 Pacific Fisheries Data Program $19.37M
81.999 Bonneville Power Administration - Environment, Fish and Wildlife $14.22M
11.022 Bipartisan Budget Act of 2021 $4.01M
15.512 Central Valley Project Improvement Act, Title Xxxiv $2.83M
11.472 Unallied Science Program $1.95M
11.407 Interjurisdictional Fisheries Act of 1986 $1.52M
15.608 Environmental Information Exchange Network Grant Program and Related Assistance $1.22M
11.436 Columbia River Fisheries Development Program $1.04M
15.661 Lower Snake River Compensation Plan $695,265
11.439 Marine Mammal Data Program $330,391
15.605 Sport Fish Restoration $213,973
15.648 Central Valley Project Improvement Act (cvpia) $150,602
11.452 Unallied Industry Products $39,971
11.427 Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program $39,051
11.441 Regional Fishery Management Councils $8,427
66.608 Puget Sound Action Agenda: Technical Investigations and Implementation Assistance Program $7,044
15.663 Nfwf-Usfws Conservation Partnership $4,822
11.438 Pacific Coast Salmon Recovery Pacific Salmon Treaty Program $22