Finding 399861 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-06-03

AI Summary

  • Core Issue: The Organization lacks a formal procurement policy that meets the requirements of 2 CFR 200.318, leading to significant deficiencies in compliance.
  • Impacted Requirements: Three transactions exceeded the $10,000 micro-purchase threshold without adequate documentation, violating procurement standards.
  • Recommended Follow-Up: Update the procurement policy to align with Uniform Guidance and ensure proper documentation for all transactions.

Finding Text

Procurement Policy Federal Agency: U.S. Department of the Treasury Federal Program Title: NeighborWorks® America Grant Cluster Federal Assistance Listing Number: 21.U12 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or Specific Requirement: The Organization should have a formal procurement policy to guide the Organization when entering into covered transactions. The policy needs to include all components identified in 2 CFR 200.318. Condition: The Organization had 3 expenses applied to the grant in excess of the $10,000 required micro-purchase threshold and below their internal $15,000 policy. The Organization also did not have a procurement policy in place that follows Uniform Guidance. Questioned Costs: None Context: The Organization had an internal procurement policy in effect that specified procurement controls and documentation for purchases greater than $15,000, which exceeds the $10,000 micro-purchase threshold required under Uniform Guidance. The Organization entered into three transactions below their $15,000 internal policy but in excess of the $10,000 required micro purchase threshold for which an adequate number of price or rate quotes were not documented. Cause: Management Oversight Effect: The effect of not having a procurement policy with all the required components would be noncompliance with 2 CFR 200.318. Recommendation: It is recommended that the Organization review and update the procurement policy as necessary to ensure compliance with the Uniform Guidance. Views of Responsible Officials: There is no disagreement with the audit finding. Refer to the Organization’s Corrective Action Plan for more information.

Corrective Action Plan

Procurement Policy Action taken in response to finding: In response to the above finding related to procurement the staff team at the organization has already researched the procurement requirements and developed a policy to comply with Uniform Guidance. The policy was reviewed by all our department leaders and feedback was collected from our finance committee and implemented into the policy. The new procurement policy was presented to our Board of Directors at the same meeting as our 2023 Financial Statement Audit (May 30, 2024) and was reviewed and approved. Following approval of the policy by the Board of Directors the CFO will hold one or multiple meetings with NeighborWorks Green Bay’s leadership team to present the changes in the policy and plan any process adjustments needed to comply with the updated policy. The new policy and process changes will then be presented to all staff and specific changes will be shared then and worked through during individual team meetings for all departments to ensure the new policy is understood and will be complied with. The approved vendor list will also be developed and finalized. We expect that the new policy will be in effect and followed for all purchases within 90 days of our Board’s acceptance of the 2023 Financial Statement Audit and this corrective action plan. Since this policy will be new to our organization, the CFO will review procurement documentation in detail for all purchases over the micro-purchase threshold of $10,000 for the first three months following the implementation of the policy and then conduct a review on a sample of transactions thereafter through the end of 2024. Any deviation from the policy will result in additional training with the entire staff or specific department as applicable.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 976303 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.U12 Neighborworks America $496,076
14.239 Home Investment Partnerships Program $198,267
21.019 Coronavirus Relief Fund $70,000
14.218 Community Development Block Grants/entitlement Grants $42,715
14.169 Housing Counseling Assistance Program $29,000
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $22,922