FAC Explorer

Finding 27969 (2022-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-04-27
Audit: 23914
Organization: Dakota Plains Legal Services, Inc. (SD)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance related to procurement procedures.
  • Impacted Requirements: Non-Federal entities must follow documented procurement procedures as per 45 CFR 1631, especially when transactions exceed the micro-purchase threshold.
  • Recommended Follow-Up: Management should enhance oversight to ensure all procurement evaluations are documented and retained to demonstrate compliance.

Finding Text

2022-003 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Procurement Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1631 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law. Condition: Our testing detected five instances in which the transaction exceeded the DPLS?s micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing DPLS?s considerations over the procurement process. Effect: Without completing a written evaluation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 60 disbursements. Out of the 60 disbursements, five items exceeded DPLS? micro-purchase threshold. Repeat Finding from Prior Year: Yes. 2021-003 reported a similar finding over procurement. Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Views of Responsible Officials: Management is in agreement.

Corrective Action Plan

Legal Services Corporation CFDA #09-742018 Legal Services Corporation- Basic Field- General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Procurement Material Weakness in Internal Control over Compliance 2022-003 Condition: The auditor's testing detected five instances in which the transaction exceeded the DPLS's micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Auditor's Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Management's Response: Management will work to ensure that all qualified transactions that exceed the micro-purchase threshold, will contain the proper documentation with regards to quotes, evaluations, and other factors which determined the selection of a particular service, product, or vendor. Responsible Individuals: Tom Mortland, Executive Director Anticipated Completion Date: December 31, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 27970 2022-004
    Significant Deficiency Repeat
  • 27971 2022-005
    Significant Deficiency Repeat
  • 27972 2022-006
    Significant Deficiency Repeat
  • 27973 2022-003
    Material Weakness Repeat
  • 27974 2022-004
    Significant Deficiency Repeat
  • 27975 2022-005
    Significant Deficiency Repeat
  • 27976 2022-006
    Significant Deficiency Repeat
  • 604411 2022-003
    Material Weakness Repeat
  • 604412 2022-004
    Significant Deficiency Repeat
  • 604413 2022-005
    Significant Deficiency Repeat
  • 604414 2022-006
    Significant Deficiency Repeat
  • 604415 2022-003
    Material Weakness Repeat
  • 604416 2022-004
    Significant Deficiency Repeat
  • 604417 2022-005
    Significant Deficiency Repeat
  • 604418 2022-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
09.742 Basic Field Grant - Native American $1.15M
09.742 Basic Field Grant - Basic $570,744
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $44,066
16.815 Tribal Civil and Criminal Legal Assistance Grants, Training and Technical Assistance $40,583
09.742 Covid-19 Response Grant $9,387