Finding Text
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP3395, 2023
Award Period: 1/1/2023 – 12/31/2026
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. 2 CFR 200.303 requires that the entity have sufficient controls over compliance related to federal awards/
Condition: In our testing for the COVID-19 State and Local Fiscal Recovery Funds procurements, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented.
Questioned Costs: ALN 21.027 - $33,266.48
Context: Out of five procurement which were tested, we noted two for which the City did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor.
Cause: These procurements occurred prior to the City implementing its new Uniform Guidance for Federal Awards policy.
Effect: The City was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions.
Repeat Finding: Yes, 2022-003.
Recommendation: We recommend the City reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement.
Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The City will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so it’s clear what considerations were made in the procurement decision.