Finding Text
2022-004: Procurement, Small Purchase - Material Weakness over Internal Controls over Compliance and Material Noncompliance Federal Program Title and Year: Emergency Solutions Grant Program, 2021 ALN: 14.231 Federal Awarding Agency: HUD Pass-Through Entity: New Mexico Mortgage Finance Authority Pass-Through Identifying Number: 21-02-SES-EHA-001 Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, a non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.320(a)(2)(i) Small purchase procedures - The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Condition: The Organization did not follow small purchase procedures for purchases that need to obtain three quotes in as noted in their policy. Cause: The Organization did not follow its procurement policy to ensure purchases had proper approval or attained the quotes needed. Effect: The Organization may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items under the small purchase threshold. Questioned Costs: Known questioned costs of $86,930 for small purchases that did not have quotes. Likely questioned costs of $184,444 consisting of all small purchases charged to the major program. Auditors? Recommendation: We recommend the Organization enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years and that they create a tool to assist in tracking and maintaining equipment purchased with federal funds.