Finding 44357 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-11-14
Audit: 40493
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Organization failed to retain documentation for a noncompetitive procurement, violating 2 CFR section 200.320(c).
  • Impacted Requirements: Compliance with Uniform Guidance is critical for maintaining eligibility for federal funding.
  • Recommended Follow-Up: Implement a process to ensure proper documentation and approval for all noncompetitive procurements moving forward.

Finding Text

Department of Energy, passed through Colorado Governor's Energy Office, Weatherization Assistance for Low-Income Persons/CFDA Number 81.042 for year ended June 30, 2022 Procurement Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR section 200.320(c), Noncompetitive Procurement, establishes there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can be awarded if the item/service is available only from a single source. Condition: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained for one instance of a single-source vendor for services provided. Cause: In discussing the condition with the Organization?s personnel, the vendor was considered a single source, but proper documentation to this consideration was not maintained. Effect: Noncompliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 40 transactions out of 684 total transactions were selected for procurement testing. Repeat Finding from Prior Years: No. Recommendation: The Organization should ensure documentation of compliance with all the requirements of Uniform Guidance, including 2 CFR section 200.320(c), Noncompetitive Procurement. We recommend that the Organization review, approve, and document process for any vendors which would qualify for noncompetitive procurement in the future. Views of Responsible Officials: Management agrees with the finding and will implement changes through a corrective action plan to ensure proper review, approval, and documentation of procurement policy.

Corrective Action Plan

Finding: 2022-001 Federal Agency Name: Department of Energy, passed through Colorado Governor?s Energy Office Program Name: Weatherization Assistance for Low-Income Persons CFDA #81.042 Finding Summary: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained on one instance of single-source vendor for services provided. Responsible Individuals: Emilee Powell, Executive Director and Marcy Child, Weatherization Program Director Corrective Action Plan: Housing Resources of Western Colorado will utilize a procurement checklist to ensure that all required procurement actions are undertaken and all required documentation is obtained for procuring contracts over the micro-purchase threshold under federal awards, in order to comply with Housing Resources? procurement policy and federal compliance requirements and will conduct additional training to ensure that all staff understand which actions are considered procurement actions. Implementation date: November 1st, 2022.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 620799 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.568 Low-Income Home Energy Assistance $863,932
81.042 Weatherization Assistance for Low-Income Persons $722,790
21.116 Congressional Appropriation - Neighborhoodworks System Program $270,036
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $261,419
10.420 Rural Self-Help Housing Technical Assistance $238,975
14.231 Emergency Solutions Grant Program $228,194
14.239 Home Investment Partnerships Program $77,780
14.218 Community Development Block Grants/entitlement Grants $64,676
93.569 Community Services Block Grant $49,977
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $14,688