Finding Text
Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: Michigan Department of Treasury Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Significant deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The County did not follow controls related to ensuring procurement policies were followed. Questioned Costs None. Context There were 55 transactions that exceeded procurement thresholds during the granting period. The sample size selected tested was 19. During our testing, it was noted on 6 of the 19 items tested that Dickinson County, Michigan was not following the requirements under the adopted procurement policies. Cause The County did not follow the requirements under the adopted procurement policies. Effect The County is not in compliance with procurement requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding No. Recommendation We recommend the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials There is no disagreement with the finding.