Finding 204829 (2022-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-28
Audit: 174148
Organization: City of Clinton (MN)

AI Summary

  • Core Issue: The City lacks a written procurement and conflict of interest policy, leading to noncompliance with federal regulations.
  • Impacted Requirements: The absence of a policy violates Title 2 U.S. Code of Federal Regulations § 200.303 and § 200.318, which mandate effective internal controls and adherence to procurement standards.
  • Recommended Follow-Up: The City should adopt a compliant procurement policy and establish controls to ensure adherence to it.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Water and Waste Disposal Systems for Rural Communities Assistance Listing Number: 10.760 Federal Award Identification Number and Year: CPAP0000001243051 - 2022, CPAP0000001243052 ? 2022 Award Period: January 1, 2022 to December 31, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Procurement Policy Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations ? 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In addition, Title 2 U.S. Code of Federal Regulations ? 200.318 states that the nonfederal entity must use its own documented procurement procedures which reflect applicable state, local and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation. Condition: The City does not have a written procurement or conflict of interest policy that include components required by Title 2 U.S. Code of Federal Regulations ? 200.318. Questioned Costs: None. Context: The City does not have a federal procurement policy. Cause: The City has not approved a procurement policy that meets the requirements of the Uniform Guidance. Effect: Noncompliance with uniform grant guidance. Repeat Finding: Yes ? 2021-006. Recommendation: We recommend the City adopt a procurement policy that meets the requirements of the Uniform Guidance and implement controls to ensure it is being followed. View of Responsible Official: There is no disagreement with the finding.

Corrective Action Plan

Water and Waste Disposal Systems for Rural Communities ? Assistance Listing No. 10.760 Recommendation: We recommend the City approve a procurement policy that meets the requirements of the Uniform Guidance and implement controls to ensure it is being followed. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The City will approve a federal procurement policy and implement controls to ensure it is being followed. Official Responsible for Corrective Action: Kari Wiegman, City Clerk/Treasurer. Planned Completion Date for Corrective Action Plan: December 31, 2023.

Categories

Procurement, Suspension & Debarment Material Weakness

Other Findings in this Audit

  • 204830 2022-006
    Material Weakness Repeat
  • 781271 2022-005
    Material Weakness Repeat
  • 781272 2022-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.760 Water and Waste Disposal Systems for Rural Communities $3.09M
97.044 Assistance to Firefighters Grant $186,095