FAC Explorer

Finding 391439 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-01
Audit: 301919
Organization: County of Nevada (CA)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County failed to comply with federal procurement and suspension regulations, leading to potential risks in transactions.
  • Impacted Requirements: Lack of documentation for emergency procurements and absence of suspension checks before transactions violate federal and County policies.
  • Recommended Follow-Up: Implement controls for compliance, create standard justification forms for noncompetitive procurements, and update purchasing policies for clarity on verification procedures.

Finding Text

Criteria or specific requirement: According to § 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to § 200.318 General procurement standards of 2 CFR Part 200, the nonfederal 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. According to § 200.320 Methods of procurement to be followed of 2 CFR Part 200, when the value of the procurement for property or services under a federal financial assistance award exceeds the SAT, or a lower threshold established by a nonfederal entity, formal procurement methods are required. According to § 180.300 of Subpart C - Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. According to Section 3.4 Formal Solicitations of the County's Purchasing Policy, Purchases of goods and services with an estimated cost of $25,000 or more (including tax, installation, and freight), shall be made as the result of a Formal Solicitation process including but not limited to Invitations for Bids, Requests for Proposals, Requests for Qualifications, Requests for Information and any other formal solicitation method that can be completed within a timeframe that allows for the solicitation, evaluation and approval in accordance with this Section. Formal solicitations may be solicited through Purchasing’s web based system or as otherwise directed by the Purchasing Agent. According to Section 3.5 Exceptions to Competitive Solicitation of the County's Purchasing Policy, in certain circumstances competitive solicitations may not be the most cost-effective approach for procurement. The Board of Supervisors, County Executive, or Purchasing may waive requirements for competitive solicitations in accordance with the grounds permitted by law. Key exemption categories are identified in the Purchasing Policy. Exceptions are not intended to circumvent the competitive process and related County policies and does not eliminate the need to ensure purchases are competitively priced and the terms and conditions of the purchase are in the best interests of the County. A written determination of the basis for the exception to competitive solicitation and the reason for the selection of the particular source shall be included in Purchasing’s records. According to the County's suspension and debarment verification process, prior to entering into an applicable contract or subrecipient agreement, department will verify on SAM.gov if an entity is listed as suspended or debarred. Condition: The County did not follow federal procurement and suspension and debarment regulation nor its purchasing policy and suspension and debarment verification procedures. Questioned costs: None Context: During our testing, we noted the following matters related to procurement and suspension and debarment. Assistance Listing Number 21.027 • For one of eleven procurements, there is no written justification, documentary support, nor evidence of approval of the emergency procurement in the procurement file. Assistance Listing Number 93.323 • For one of two procurements, the County did not maintain evidence of the suspension and debarment check before entering into the covered transaction or evidence of the review and approval of the verification check. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in procurement transactions for the acquisition of property or services required under a federal award not conducted in a manner providing full and open competition and other general procurement standards, as applicable. Also, noncompliance results in procurement transactions with potentially suspended or debarred entities. Repeat Finding: This audit finding was reported in the prior year in finding 2022-004. Recommendation: We recommend the County design controls to ensure compliance with federal procurement and suspension and debarment regulation and its purchasing policy and suspension and debarment verification procedures. We recommend the County develop standard justification forms with approval of the noncompetitive procurement documented on the forms and the forms maintained in the procurement file. Also, we recommend the County update its purchasing policy to ensure clear, concise, and detailed suspension and debarment verification procedures. Views of responsible officials: There is no disagreement from responsible officials

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 391403 2023-002
    Significant Deficiency Repeat
  • 391404 2023-002
    Significant Deficiency Repeat
  • 391405 2023-002
    Significant Deficiency Repeat
  • 391406 2023-002
    Significant Deficiency Repeat
  • 391407 2023-002
    Significant Deficiency Repeat
  • 391408 2023-002
    Significant Deficiency Repeat
  • 391409 2023-002
    Significant Deficiency Repeat
  • 391410 2023-002
    Significant Deficiency Repeat
  • 391411 2023-002
    Significant Deficiency Repeat
  • 391412 2023-002
    Significant Deficiency Repeat
  • 391413 2023-002
    Significant Deficiency Repeat
  • 391414 2023-002
    Significant Deficiency Repeat
  • 391415 2023-002
    Significant Deficiency Repeat
  • 391416 2023-002
    Significant Deficiency Repeat
  • 391417 2023-002
    Significant Deficiency Repeat
  • 391418 2023-002
    Significant Deficiency Repeat
  • 391419 2023-002
    Significant Deficiency Repeat
  • 391420 2023-002
    Significant Deficiency Repeat
  • 391421 2023-002
    Significant Deficiency Repeat
  • 391422 2023-002
    Significant Deficiency Repeat
  • 391423 2023-002
    Significant Deficiency Repeat
  • 391424 2023-002
    Significant Deficiency Repeat
  • 391425 2023-002
    Significant Deficiency Repeat
  • 391426 2023-003
    Material Weakness Repeat
  • 391427 2023-003
    Material Weakness Repeat
  • 391428 2023-002
    Significant Deficiency Repeat
  • 391429 2023-002
    Significant Deficiency Repeat
  • 391430 2023-002
    Significant Deficiency Repeat
  • 391431 2023-002
    Significant Deficiency Repeat
  • 391432 2023-004
    Material Weakness Repeat
  • 391433 2023-004
    Material Weakness Repeat
  • 391434 2023-004
    Material Weakness Repeat
  • 391435 2023-004
    Material Weakness Repeat
  • 391436 2023-002
    Significant Deficiency Repeat
  • 391437 2023-002
    Significant Deficiency Repeat
  • 391438 2023-003
    Material Weakness Repeat
  • 967845 2023-002
    Significant Deficiency Repeat
  • 967846 2023-002
    Significant Deficiency Repeat
  • 967847 2023-002
    Significant Deficiency Repeat
  • 967848 2023-002
    Significant Deficiency Repeat
  • 967849 2023-002
    Significant Deficiency Repeat
  • 967850 2023-002
    Significant Deficiency Repeat
  • 967851 2023-002
    Significant Deficiency Repeat
  • 967852 2023-002
    Significant Deficiency Repeat
  • 967853 2023-002
    Significant Deficiency Repeat
  • 967854 2023-002
    Significant Deficiency Repeat
  • 967855 2023-002
    Significant Deficiency Repeat
  • 967856 2023-002
    Significant Deficiency Repeat
  • 967857 2023-002
    Significant Deficiency Repeat
  • 967858 2023-002
    Significant Deficiency Repeat
  • 967859 2023-002
    Significant Deficiency Repeat
  • 967860 2023-002
    Significant Deficiency Repeat
  • 967861 2023-002
    Significant Deficiency Repeat
  • 967862 2023-002
    Significant Deficiency Repeat
  • 967863 2023-002
    Significant Deficiency Repeat
  • 967864 2023-002
    Significant Deficiency Repeat
  • 967865 2023-002
    Significant Deficiency Repeat
  • 967866 2023-002
    Significant Deficiency Repeat
  • 967867 2023-002
    Significant Deficiency Repeat
  • 967868 2023-003
    Material Weakness Repeat
  • 967869 2023-003
    Material Weakness Repeat
  • 967870 2023-002
    Significant Deficiency Repeat
  • 967871 2023-002
    Significant Deficiency Repeat
  • 967872 2023-002
    Significant Deficiency Repeat
  • 967873 2023-002
    Significant Deficiency Repeat
  • 967874 2023-004
    Material Weakness Repeat
  • 967875 2023-004
    Material Weakness Repeat
  • 967876 2023-004
    Material Weakness Repeat
  • 967877 2023-004
    Material Weakness Repeat
  • 967878 2023-002
    Significant Deficiency Repeat
  • 967879 2023-002
    Significant Deficiency Repeat
  • 967880 2023-003
    Material Weakness Repeat
  • 967881 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 - Coronavirus Local Fiscal Recovery Funds $3.50M
14.239 Home Investment Partnership Program $2.66M
10.561 Calfresh Admin $2.36M
93.558 Temporary Assistance for Needy Families: Calworks Cec Programs-Sa $2.33M
66.956 Targeted Airshed Grant Program: 2019-20 Targeted Airshed Grant $2.20M
93.778 Medical Assistance Program: Maa Admin $2.11M
21.027 Covid-19 - Coronavirus Local Fiscal Recovery Funds Behavioral Health Continuum Infrastructure Program $2.00M
93.563 Child Support Services: Child Support Services $1.76M
93.558 Temporary Assistance for Needy Families: Calworks All Families/zero Parent $1.67M
93.659 Adoption Assistance: Adoption Assistance $1.43M
93.558 Temporary Assistance for Needy Families: Calworks Cec Programs-Non Sa $1.15M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases: Elc Enhanced Detection $771,353
20.509 Formula Grants for Rural Areas: Fta 5311 Crrsaa $768,114
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance: Grants for the Benefit of Homeless Individuals $727,530
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $716,508
93.959 Block Grants for Prevention and Treatment of Substance Abuse: Substance Abuse Prevention and Treatment $709,363
93.658 Foster Care Title IV-E: Cws IV-E $695,448
93.505 Affordable Care Act (aca) Maternal, Infant, and Early Childhood Home Visiting Program: Chvp Miechv $686,831
93.558 Temporary Assistance for Needy Families: Calworks Hsp $651,603
93.958 Block Grants for Community Mental Health Services: Community Mental Health Centers $622,058
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases: Elc Expansion $615,141
93.778 Medical Assistance Program: Maa, Public Health $587,246
20.509 Formula Grants for Rural Areas: Fta 5311 Statewide Rural Public Transit $575,865
20.205 Highway Planning and Construction: Local Assistance Program - Guardrail Safety Audit Project $568,494
14.228 Community Development Block Grants $536,100
20.509 Formula Grants for Rural Areas: Fta 5311 $518,113
93.667 Social Services Block Grant: In-Home Supportive Services $468,775
93.268 Immunization Cooperative Agreements: Immunizations $458,954
93.658 Foster Care Title IV-E: Foster Care Assistance $404,665
93.558 Temporary Assistance for Needy Families: Child Care $399,029
93.958 Block Grants for Community Mental Health Services: Crisis Care Mobile Unit $395,110
20.205 Highway Planning and Construction: Local Assistance Program - Highway Bridge Program - Dog Bar Road at Bear River Bridge Replacement $388,133
14.228 Community Development Block Grants: Cdbg-Cv-3 $365,571
20.205 Highway Planning and Construction: Local Assistance Program - Highway Bridge Program - Hirschdale at Truckee River Bridge $258,838
97.036 Disaster Grants, Public Assistance: Dr 4610 $256,546
93.959 Covid-19 - Block Grants for Prevention and Treatment of Substance Abuse: Substance Abuse Prevention and Treatment Crrsaa $247,779
93.958 Covid-19 - Block Grants for Community Mental Health Services: Mhbg Arpa $241,958
93.558 Temporary Assistance for Needy Families: Cws Tanf $233,740
93.778 Medical Assistance Program: California Children's Services $233,153
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities: Fta 5310 $224,000
14.228 Community Development Block Grants: Cdbg-Cv-2 $210,926
14.228 Community Development Block Grants: Cdbg-Cv1 $207,134
93.658 Foster Care Title IV-E: Foster Care Assistance Ea $193,100
16.575 Crime Victim Assistance: Victim Witness Assistance Program $192,431
93.659 Adoption Assistance: Adoption Assistance Ffcra $168,276
93.778 Medical Assistance Program: McAh $167,400
93.069 Public Health Emergency Preparedness: Phep $167,181
93.658 Foster Care Title IV-E: Prob IV-E & Ghmv Pt $165,597
93.569 Community Services Block Grant: Csbg $159,722
93.778 Medical Assistance Program: Health Care Program for Children in Foster Care $154,368
10.665 Schools and Roads - Grants to States: Twenty Five Percent Fund Act of 1908 $153,040
97.042 Emergency Management Performance Grants: Emergency Management Preparedness Fy21 $144,812
10.561 Calfresh Healthy Living Nutrition Education and Obesity Prevention $139,313
93.889 National Bioterrorism Hospital Preparedness Program: Hpp $135,245
93.658 Foster Care Title IV-E: Admin of Children & Families $126,073
93.658 Foster Care Title IV-E: Non Cws Allocation $122,767
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance: Samhsa Drug Court Expansion $120,317
14.267 Continuum of Care Program: Home Anew $114,000
93.959 Covid-19 - Block Grants for Prevention and Treatment of Substance Abuse: Substance Abuse Prevention and Treatment Arpa $100,918
97.067 Homeland Security Grant Program: Hsgp Fy19 $97,402
93.558 Temporary Assistance for Needy Families: Calworks Fed-Gap $95,290
93.994 Maternal and Child Health Services Block Grant: McAh Fy 22/23 $92,940
93.354 Covid-19 - Public Health Emergency Response, Cooperative Agreement for Emergency Response, Public Health Crisis Response: Covid Workforce Development $87,022
20.205 Highway Planning and Construction: Local Assistance Program - No. Bloomfield at S. Yuba Replacement Project $83,409
93.658 Foster Care Title IV-E: Foster Care $82,501
93.870 Covid-19 - Maternal, Infant, and Early Childhood Home Visiting Grant: Chvp Arpa $79,161
14.241 Housing Opportunities for People with Aids: Hopwa $70,658
93.778 Medical Assistance Program: Maa Admin Activities, Veteran Services $64,190
93.667 Social Services Block Grant: Csw Title Xx $59,000
97.042 Covid-19 - Emergency Management Performance Grants: Emergency Management Preparedness Arpa $58,435
93.917 Hiv Care Formula Grant: Hiv Cares X07 $55,882
93.658 Foster Care Title IV-E: Foster Care Assistance Efc $55,339
16.575 Crime Victim Assistance: Victim Services Program $53,878
93.391 Covid-19 - Activities to Support Stlt Health Department Response to Public Health Or Healthcare Crises: Covid Health Disparities $53,383
20.106 Airport Improvement Program $46,132
93.659 Adoption Assistance: Adoptions Elig $45,401
93.556 Mary Lee Allen Promoting Safe and Stable Families Program: Pssf $44,388
93.658 Foster Care Title IV-E: Ccr Cwd $40,088
93.658 Foster Care Title IV-E: Foster Care Assistance Ffcra $34,711
20.205 Highway Planning and Construction: Local Assistance Program - Highway Bridge Program - Hirschdale at Uprr Railroad Bridge $32,902
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood: Ilp $31,580
93.569 Community Services Block Grant: Csbg Discretionary $31,000
93.659 Adoption Assistance: Adoptions Ss $29,204
10.433 Rural Housing Preservation Grants: Housing Preservation Grant $27,354
93.590 Community-Based Child Abuse Prevention Grants: Child Abuse Prevention Cbcap $25,954
93.645 Stephanie Tubbs Jones Child Welfare Services Program: Cws IV-B $25,221
93.569 Covid-19 - Community Services Block Grant: Csbg Cares $24,117
14.267 Continuum of Care Program: Winter's Haven $20,012
20.205 Highway Planning and Construction: Local Assistance Program - Soda Springs Road Bridge Over South Yuba Replacement $17,003
93.150 Projects for Assistance in Transition From Homelessness: Path $16,333
93.603 Adoption and Legal Guardianship Incentive Payments: Adoptions Incentive $13,725
16.001 Domestic Cannabis Eradication/suppression Program $12,887
93.558 Temporary Assistance for Needy Families: Calworks Fed-Gap Ffcra $11,657
93.658 Foster Care Title IV-E: Cws Furs $10,292
93.658 Foster Care Title IV-E: Eccb $9,488
93.658 Foster Care Title IV-E: Emergency Child Care Bridge Program $9,488
93.090 Guardianship Assistance: Kingap IV-E Admin $9,121
93.778 Medical Assistance Program: California Health Disability Prevention $9,095
93.747 Covid-19 - Elder Abuse Prevention Interventions Program: Aps Arpa $9,080
93.658 Foster Care Title IV-E: Licensing $8,561
10.664 Cooperative Forestry Assistance: Cooperative Law Enforcement Patrol Operating Plan $7,897
10.025 Plant & Animal Disease, Pest Control, & Animal Care: Pierce's Disease Control $7,729
93.558 Temporary Assistance for Needy Families: Calworks Kin-Gap $6,769
93.658 Foster Care Title IV-E: Foster Care Assistance Efc Ffcra $6,504
10.025 Plant & Animal Disease, Pest Control, & Animal Care: European Grapevine Moth Detection $5,071
93.558 Temporary Assistance for Needy Families: Calworks Mixed $4,068
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs: U4ukraine $3,969
93.659 Adoption Assistance: Ccr Aap Cwd $3,918
97.067 Homeland Security Grant Program: Hsgp Fy21 $3,452
20.205 Highway Planning and Construction: Local Assistance Program - Rough and Ready Intersection $3,350
93.217 Family Planning Services: Title X $2,716
15.433 Flood Control Act Lands $2,608
14.239 Home Investment Partnership Program: Home $2,578
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $2,544
93.658 Foster Care Title IV-E: Csec $1,870
93.659 Adoption Assistance: Adoption Assistance Aap+ Assistance $1,624
10.561 Calfresh Arpa $1,532
14.228 Community Development Block Grants: Cdbg-Drmhp $1,184
93.558 Temporary Assistance for Needy Families: Calworks Kin-Gap Ffrca $792
14.228 Community Development Block Grants: Cdbg $626
10.025 Plant & Animal Disease, Pest Control, & Animal Care: Sudden Oak Death $482
93.658 Foster Care Title IV-E: Ccr Cpd $294
93.659 Adoption Assistance: Prob IV-E Adopt Pt $226
93.659 Adoption Assistance: Adoption Assistance Aap+ Ffcra $201
21.032 Covid-19 - Local Assistance and Tribal Consistency Funds $0