FAC Explorer

Finding 375839 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-03-13
Audit: 294940
Organization: Green Lake County (WI)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County's procurement policy does not comply with federal requirements, lacking necessary provisions for suspension and debarment verification.
  • Impacted Requirements: Non-compliance with 2 CFR 200 regarding procurement processes and documentation, risking contracts with suspended or debarred vendors.
  • Recommended Follow-Up: Update procurement policies to align with 2 CFR 200, ensuring compliance and incorporating suspension and debarment language, along with staff training.

Finding Text

2022-004 Procurement, Suspension and Debarment Federal Assistance Listing Numbers – 21.027, 93.323 Federal Agency – Department of Treasury, Department of Health and Human Services Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 375835 2022-003
    Material Weakness
  • 375836 2022-003
    Material Weakness
  • 375837 2022-004
    Significant Deficiency
  • 375838 2022-004
    Significant Deficiency
  • 375840 2022-004
    Significant Deficiency
  • 375841 2022-006
    Material Weakness
  • 375842 2022-006
    Material Weakness
  • 375843 2022-006
    Material Weakness
  • 375844 2022-006
    Material Weakness
  • 375845 2022-006
    Material Weakness
  • 375846 2022-006
    Material Weakness
  • 375847 2022-006
    Material Weakness
  • 375848 2022-006
    Material Weakness
  • 375849 2022-006
    Material Weakness
  • 952277 2022-003
    Material Weakness
  • 952278 2022-003
    Material Weakness
  • 952279 2022-004
    Significant Deficiency
  • 952280 2022-004
    Significant Deficiency
  • 952281 2022-004
    Significant Deficiency
  • 952282 2022-004
    Significant Deficiency
  • 952283 2022-006
    Material Weakness
  • 952284 2022-006
    Material Weakness
  • 952285 2022-006
    Material Weakness
  • 952286 2022-006
    Material Weakness
  • 952287 2022-006
    Material Weakness
  • 952288 2022-006
    Material Weakness
  • 952289 2022-006
    Material Weakness
  • 952290 2022-006
    Material Weakness
  • 952291 2022-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $303,653
20.219 Recreational Trails Act Agreement $142,500
93.667 Social Services Block Grant $70,199
97.042 Emergency Management Performance Grants $59,330
10.561 State Administrative Matching Grants for Food Stamp Program $57,081
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $51,622
93.575 Child Care and Development Block Grant $45,053
20.513 Enhanced Mobility for Seniors and Individuals with Disabilities $40,787
93.069 Public Health Emergency Preparedness $35,058
93.045 Covid-19 Special Programs for the Aging Title Iii, Part C Nutrition Services $33,460
93.556 Promoting Safe and Stable Families $33,350
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $28,315
93.958 Block Grants for Community Mental Health Services $27,593
93.945 Assistance Programs for Chronic Disease Prevention and Control $25,739
93.053 Nutrition Incentive Program (nsip) $23,820
84.181 Special Education - Grants for Infants and Families $23,415
93.354 Covid-19 Public Health Crisis Response Awards $22,826
93.045 Special Programs for the Aging Title Iii, Part C Nutrition Services $19,212
16.710 Anti-Heroin Task Force Grant $16,353
93.658 Foster Care (title IV-E) $13,084
93.435 Innovative State and Local Public Health Strategies to Prevent and Manage Diabetes and Heart Disease and Stroke $12,580
93.052 National Family Caregiver Support, Title Iii, Part E $12,138
93.556 Covid-19 Promoting Safe and Stable Families $11,442
93.324 State Health Assistance Program $10,500
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $10,120
93.994 Maternal and Child Health Services Block Grant to the States $10,015
93.767 Children's Health Insurance Program $9,449
93.959 Block Grants for Prevention and Treatment of Substance Abuse $8,213
93.991 Preventative Health and Health Services Block Grant $7,510
93.268 Immunization Cooperative Agreements $6,000
93.071 Medicare Enrollment Assistance Program $5,868
93.070 Environmental Public Health and Emergency Response $5,500
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $5,000
93.268 Covid-19 Immunization Cooperative Agreements $4,934
93.090 Dsp Subsidized Guardianship $3,090
93.659 Adoption Assistance $3,042
93.747 Covid-19 Elder Abuse Prevention Interventions Program $3,027
93.558 Temporary Assistance for Needy Families $2,879
93.043 Special Programs for the Aging Title Iii, Part D Disease Prevention and Health Promotion Services $2,440
93.645 Stephanie Tubbs Jones Child Welfare Services Program $797
10.561 Covid-19 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $635
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $271
93.563 Child Support Enforcement (title IV-D) $115
93.044 Covid- 19 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $-271