Finding Text
2022-009 – Procurement Documentation
Finding Type: Significant Deficiency in Internal Controls and Noncompliance (Procurement,
Suspension & Debarment)
Federal Program: U.S. Department of Treasury – Coronavirus State and Local Fiscal Recovery
Funds (AL #21.027)
Criteria: The Code of Federal Regulations (CFR) Section 200.318(a) requires non-Federal entities to establish and use documented procurement procedures that conform to the procurement standards identified in Sections 200.317 through 200.327.
Condition: While the County does have a written procurement policy that meets the requirements, the policy was not being followed. The County did not maintain records sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The County did not maintain documentation to sufficiently support noncompetitive procurement on one contract tested. The County did not maintain written documentation of a cost analysis. County management indicated that many of the items procured were processed through the Michigan MiDeal website, but a contract file was not maintained.
Cause: The County does not have controls in place to ensure that its procurement policy is being followed.
Effect: As a result of this condition, the County did not fully comply with the Uniform Guidance.
Questioned Costs: No costs have been questioned as a result of this finding.
Recommendation: We recommend that the County implement controls to ensure the procurement policy is followed.
Views of Responsible Officials: The County will work to implement controls to ensure the procurement policy is followed.