Finding Text
Identification of the federal program - U.S. Department of the Treasury, Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds. Type of Finding - Significant Deficiency in Internal Controls over Compliance over Procurement. Criteria or specific requirement - Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in 42 USC Sections 802(c) and 803(c) and Treasury’s Interim Final Rule and Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance (2 CFR 200.317 through 2 CFR 200.327). Specifically, as per 2 CFR 200.320(a)(2), Methods of Procurement to be Followed, Informal Procurement Methods for Small Purchases, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Condition - In the auditor’s testing of program transactions subject to procurement standards, the auditor identified two transactions where supporting documentation for all rate quotations solicited and obtained was not fully maintained. Cause - A breakdown in the Corporation’s internal controls over procurement resulting from turnover in personnel responsible for obtaining rate quotations. Effect or potential effect - Supporting documentation for all rate quotations solicitated and obtained is not always available to be reviewed by a third party, which would assist in the understanding of procurement decisions made and determination of compliance with procurement standards under the Uniform Guidance. Questioned costs - There were no questioned costs identified. Context - Rate quotations and contracts for selected vendors were maintained for procurement transactions, however, solicited rate quotations from alternative vendors were not maintained. Recommendation - We recommend that the Corporation clarify and enhance its procurement policies and procedures, which would include requirements to maintain all price quotations on file. Views of responsible officials - On November 23, 2023, Mental Health Connecticut, Inc. and Subsidiary updated its Procurement Policy to require formal documentation of all rate quotes related to federal funding in accordance with federal procurement standards. This updated policy was then shared with Mental Health Connecticut, Inc. and Subsidiary personnel responsible for contracting for services and has been implemented for transactions after this date.