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Finding 2022-004 ? Significant Deficiency Assistance Listing: 21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Federal Grantor: Department of the Treasury Compliance Requirement: Procurement and Suspension and Debarment Condition: The District used a sole source authorization for the procurement of a Type-1 Fire Engine but a competitive bid process should have been used to comply with Uniform Guidance. Criteria: Non-state entities under the program, must follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. Specifically, procurements in excess of $250,000 be conducted using a competitive procurement method such as bids or proposals. Further, the District?s Purchasing Policy Sec 2112.13 requires staff obtain competitive bids for the purchase of supplies, equipment or service that are $15,000 or greater. Interagency or cooperative purchasing agreements may be leveraged, but they must comply with the Unform Standards, and 2 CFR section 200.320(c) states noncompetitive procurement can only be awarded if one or more of the following circumstances apply: 1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); 2) The item is available only from a single source; 3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; 4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or 5) After solicitation of a number of sources, competition is determined inadequate. Cause: The District?s Purchasing Policy allows for a sole source vendor with the approval of the Chief Administrative Officer. In addition, the Policy allows the District to purchase through a purchasing alliance, such as a cooperative agreement. The sole source vendor has a cooperative purchasing agreement through National Purchasing Partners (NPP) cooperative, contract number PS20240. The District?s justification for sole source vendor was uniformity of vendors across safety equipment which fosters ease of operator training and emergency scene efficiency. The approval indicated standardization also supports ongoing maintenance of the fleet. While permitted by internal policy, this justification does not appear to meet any of the noncompetitive procurement exceptions allowed by the Uniform Standards outlined above. The District was also unable to provide documentation that the vendor purchasing agreement through NPP complies with the Uniform Standards for procurement. Effect: Treasury may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 C.F.R. ? 200.339. Recommendation: We recommend the District work with FEMA to obtain written approval for the sole source procurement, which is one of the exceptions to noncompetitive procurements. Views of Responsible Officials and Planned Corrective Actions: Management?s response and planned corrective action is included in the Corrective Action Plan included at the end of the report.