Finding 393658 (2023-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-17

AI Summary

  • Core Issue: The entity lacks documented procurement policies for federal funding, leading to potential compliance risks.
  • Impacted Requirements: Failure to meet 2 CFR §200.318 standards, including documentation for contractor selection and vendor verification.
  • Recommended Follow-Up: Develop and implement procurement policies per Uniform Guidance and ensure documentation of vendor checks and procurement decisions.

Finding Text

Federal Agency: Department of Treasury Assistance Listing Number and Title: 21.027 – Coronavirus State and Local Fiscal Recovery Funds Funding Year(s): 2023-2026 Criteria: Per 2 CFR §200.318, General procurement standards, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at a minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: For our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor. Questioned Costs: None noted. Cause: The entity has written policies for construction procurements, including requirements to obtain at least 2 competitive bids for projects over $5,000 and two proposals for architectural services over $100,000. The entity’s policies also require use of American Institute of Architects contract agreements for construction projects among other requirements. However, the entity does not have policies and procedures designed for procurements under the Uniform Guidance, and therefore, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Effect: Costs charged to federal awards without appropriate documentation of procurement policies and processes may be subject to disallowance. Repeat Finding: No. Recommendation: We recommend developing written procurement policies in accordance with the Uniform Guidance and implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend retaining documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Officials: Management notes the details of this finding and the resulting material weakness. Management will enact processes outlined in our Corrective Action Plan to correct this deficiency in the future.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 393655 2023-002
    Material Weakness Repeat
  • 393656 2023-003
    Material Weakness
  • 393657 2023-002
    Material Weakness Repeat
  • 970097 2023-002
    Material Weakness Repeat
  • 970098 2023-003
    Material Weakness
  • 970099 2023-002
    Material Weakness Repeat
  • 970100 2023-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $752,369
64.024 Va Homeless Providers Grant and Per Diem Program $689,839
93.959 Block Grants for Prevention and Treatment of Substance Abuse $663,443
21.027 Coronavirus State and Local Fiscal Recovery Funds $468,890
97.088 Disaster Assistance Projects $206,145
14.267 Continuum of Care Program $72,252
14.231 Emergency Solutions Grant Program $50,036
10.565 Commodity Supplemental Food Program $33,485
93.788 Opioid Str $5,236
97.024 Emergency Food and Shelter National Board Program $1,547