Finding 366880 (2023-001)

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Requirement
I
Questioned Costs
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Year
2023
Accepted
2024-02-12
Audit: 289984
Organization: Polk County (OR)
Auditor: Singerlewak LLP

AI Summary

  • Core Issue: The County did not follow required formal procurement procedures for purchasing a jail camera system, violating 2 CFR 200.320.
  • Impacted Requirements: The County's internal policies were less strict than federal requirements, leading to a lack of open competition.
  • Recommended Follow-Up: Implement formal procurement processes for all federal purchases exceeding the simplified acquisition threshold and develop a corrective action plan.

Finding Text

Identification of Federal Program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate. Condition The County did not follow formal procurement procedures related to the purchase of jail camera system. Cause The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320. Potential Effect Open competition was not insured. Questioned Costs None Context The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed. Identification of a repeat finding, if applicable This is a new finding for the County Recommendations Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold. Views of Responsible Officials The County agrees with the finding and will develop a corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.02M
97.067 Homeland Security Grant Program $321,990
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $321,568
15.605 Sport Fish Restoration Program $256,803
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $255,428
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $240,641
93.563 Child Support Enforcement $202,436
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $199,078
93.268 Immunization Cooperative Agreements $195,991
16.575 Crime Victim Assistance $168,649
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $109,194
93.069 Public Health Emergency Preparedness $91,804
97.042 Emergency Management Performance Grants $84,206
93.959 Block Grants for Prevention and Treatment of Substance Abuse $74,884
93.958 Block Grants for Community Mental Health Services $62,381
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $42,209
93.994 Maternal and Child Health Services Block Grant to the States $35,018
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $28,674
93.217 Family Planning_services $22,854
20.600 State and Community Highway Safety $11,763
15.659 National Wildlife Refuge Fund $10,672
15.999 Scotch Broom Removal and Dump Stoppers $9,420
16.034 Coronavirus Emergency Supplemental Funding Program $7,484
16.607 Bulletproof Vest Partnership Program $6,715
20.616 National Priority Safety Programs $4,214
39.003 Donation of Federal Surplus Personal Property $1,400
10.665 Schools and Roads - Grants to States $875