Finding 401876 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-06-25

AI Summary

  • Core Issue: The Organization lacks documentation for its noncompetitive procurement process, particularly for sole source contracts.
  • Impacted Requirements: Federal compliance mandates consistent procurement policies and checks for contractor suspension or debarment, which were not fully followed.
  • Recommended Follow-Up: Ensure documentation of procurement processes is retained, including vendor checks against federal databases like www.sam.gov.

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 401874 2023-001
    Significant Deficiency
  • 401875 2023-002
    Significant Deficiency
  • 401877 2023-002
    Significant Deficiency
  • 978316 2023-001
    Significant Deficiency
  • 978317 2023-002
    Significant Deficiency
  • 978318 2023-001
    Significant Deficiency
  • 978319 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.307 Economic Adjustment Assistance $404,756
21.027 Coronavirus State and Local Fiscal Recovery Funds $198,271
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $48,130