Finding Text
2023-001 – Documentation of Procurement Process
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment).
Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027.
Criteria. A recipient of federal awards is required to apply procurement policies and procedures consistently for federal and non-federal transactions. In addition, when using a contractor for $25,000+ in services, the entity is required to determine whether the contractor has been suspended or debarred by the federal government.
Condition. The Organization does not have documentation of their process for noncompetitive procurement, specifically related to sole source procurement. In addition, the Organization reviews vendors standing with the State of Michigan and LARA, but not with www.sam.gov. No documentation of this review is retained.
Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant.
Effect. As a result of this condition, the Organization did not fully comply with the requirements of the Uniform Guidance.
Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted.
Recommendation. We recommend that the Organization retain documentation of their procurement process including checking vendors for potential exclusions from federal award work.
View of Responsible Officials. LEAP has recently learned, through this audit process and a non-material note, that it can continue to improve its process for non-competitive procurement, specifically related to sole source procurement. We welcome the opportunity to modify documentation in 2024.