Finding Text
Finding 2021-010 Sole Source Vendors - Procurement and Suspension and Debarment –
Material Noncompliance and Material Weakness in Internal Control Over
Compliance
Agency Environmental Protection Agency
ALN 66.202
Program Congressionally Mandated Projects
Award Year FY 2021
Pass-Through Agency State of Alaska Department of Environmental Conservation
Pass-Through Entity
Identifying Number(s)
18EQ57, 20ER77, 21ES93
Criteria 2 CFR 200.320 states the non-federal entity must have and used
documented procurement procedures consistent with 2 CFR 200.317-.319,
and identifies the methods of procurement to be followed. 2 CFR
200.320(c) states the specific circumstances in which noncompetitive
procurement can be used.
Condition During our testing of procurement and suspension and debarment, we
noted the following exception: One of the three procurement transactions
tested was procured via sole source without adequate support of the
rationale to limit competition.
Cause The City’s policies and procedures were not appropriately designed to
ensure compliance with the requirements of the Uniform Guidance
concerning use of noncompetitive procurement.
Effect or potential
effect
The City was not compliant with 2 CFR 200.320 concerning specific
circumstances in which noncompetitive procurement can be used. The
incorrect use of noncompetitive procurement increases the probability
that federal funds are spent wastefully. Questioned costs $208,291
Context We tested a sample of three procurement transactions totaling to
$1,516,880 from a population of four procurement transactions totaling to
$1,560,666. We noted one exception as noted in the condition. This is a
condition identified per review of the City’s compliance with the specified
requirements not using a statistically valid sample. The known amount of
the one exception is $208,291.
Identification as a
repeat finding
Not a repeat finding.
Recommendation We recommend that the controls and processes that have been established
be implemented and to ensure the City is following its procurement policy
and meeting the Uniform Guidance compliance requirements.
Views of
responsible officials
Management agrees with the finding. The City will follow the Uniform
Guidance thresholds that are established for federal programs, as well as
follow the City Council’s policy.