Finding 20740 (2022-002)

-
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-06-29

AI Summary

  • Core Issue: The County did not properly document its procurement process, raising questions about compliance with federal and local laws.
  • Impacted Requirements: Lack of evidence that the sole source procurement method was justified and no checks on the contracting party's suspension or debarment status.
  • Recommended Follow-up: Strengthen procedures for retaining documentation on sole source contracts and ensure checks against suspension or debarment are consistently performed.

Finding Text

Criteria: The County must use it?s own documented procurement procedures, which should reflect applicable state and local laws and regulations, and must conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A contract was awarded under the provisions of sole source of procurement however, documentation relating to the award was unclear that this procurement method was appropriate under the circumstances. Additionally, no documentation of the review that the contracting party was not suspended or debarred was included in the procurement documentation. Cause: The County did not retain documentation that the procurement complied with the requirements of the procurement policy or the federal regulations relating to suspension and debarment. Effect: The County did not have evidence that it had complied with federal procurement requirements and it?s internal policy and the contract could have been awarded to a vendor that had been suspended or debarred. The granting agency could require expenditures paid with federal funds relating to this contract, be returned. Exclusion records were subsequently searched and it was determined that the contracting party was not suspended or debarred. Auditor's Recommendation: Procedures relating to retaining appropriate documentation of sole source contracts and consideration that contracting parties have not been suspended or debarred should be strengthened.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation. The Procurement Department will implement a check-list for future purchases and one of the items to be checked off is the need for a Single/Sole Source justification. Also, the Single/Sole Source Policy will be reviewed to ensure that the requirement for bidding is waived for approved justifications. These will be accomplished by August 1, 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $4.17M
20.507 Covid-19 Federal Transit_formula Grants $1.04M
14.218 Covid-19 Community Development Block Grants/entitlement Grants $532,500
14.218 Community Development Block Grants/entitlement Grants $435,314
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $226,218
16.575 Crime Victim Assistance $175,087
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $152,483
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $146,163
20.509 Formula Grants for Rural Areas and Tribal Transit Program $99,016
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $72,626
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $70,761
16.588 Violence Against Women Formula Grants $70,000
16.585 Drug Court Discretionary Grant Program $66,405
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $63,140
97.042 Emergency Management Performance Grants $25,100
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $15,043
16.922 Equitable Sharing Program $14,151
93.667 Social Services Block Grant $12,926
10.932 Regional Conservation Partnership Program $12,096
93.605 Family Connection Grants $12,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $10,014
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $9,716
20.507 Federal Transit_formula Grants $8,058
20.615 E-911 Grant Program $6,748
93.052 National Family Caregiver Support, Title Iii, Part E $6,070
93.053 Nutrition Services Incentive Program $4,778
97.039 Hazard Mitigation Grant $2,400
16.838 Comprehensive Opioid Abuse Site-Based Program $1,480
14.231 Covid-19 Emergency Solutions Grant Program $1,479