Finding 481008 (2022-003)

2022-003 U.S. Department of Treasury Federal Financial Assistance Listing # 21.027 Award Years: 2021, 2022 Grant Award Number: Unknown COVID–19 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures and contract requirements required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was noted that the City of Groton’s (the City) procurement policy followed state law which is some cases is less restrictive than federal law. We also noted that the policy does not include the required contract provisions that are needed in contracts with federal grants. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts when federal grants are involved. Questioned Costs: None reported Context/Sampling: All vendors, which totaled two, were selected for procurement testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review Uniform Guidance and 2 CFR sections 200.318 through 200.326 to ensure that all items identified are included in the procurement policy. Views of Responsible Officials: Management agrees with the finding.