Finding 497919 (2023-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-24
Audit: 320523
Organization: New Brighton Borough (PA)
Auditor: Jma LLC

AI Summary

  • Core Issue: The Borough lacks written policies for procurement procedures and conflicts of interest, violating Uniform Guidance requirements.
  • Impacted Requirements: This absence increases the risk of non-compliance with federal standards, leading to inconsistent practices and potential favoritism.
  • Recommended Follow-Up: Develop comprehensive written policies for procurement and conflicts of interest, and train staff to ensure compliance and integrity in the procurement process.

Finding Text

Criteria: The Borough is required by the Uniform Guidance to have written policies addressing procurement procedures specific to federal award expenditures and written policies specific to conflicts of interest. Condition: The Borough does not have any written policies addressing procurement procedures specific to federal award expenditures or written policies specific to conflicts of interest. Cause: The absence of these written policies appears to be due to oversight and a lack of awareness of the specific requirements under the Uniform Guidance. The municipality has relied on informal procedures and verbal guidelines for procurement and conflict of interest issues. Effect: Without formal written policies, there is a higher risk of non-compliance with federal procurement standards. This lack of documentation can lead to inconsistent procurement practices, potential favoritism, and conflicts of interest, which may result in unallowable costs, inefficiencies, and jeopardize the integrity of the procurement process. Recommendation: We recommend that the Borough develop and implement comprehensive written procurement policies and conflict of interest policies that comply with the Uniform Guidance. These policies should include: Procurement Policies: Clear procedures for procurement planning, solicitation, evaluation, and award. Methods of procurement to be used, including micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals. Procedures to ensure compliance with the applicable federal requirements for procurement. Conflict of Interest Policies: Definitions and examples of conflicts of interest. Procedures for disclosing potential conflicts of interest. Actions to be taken when conflicts of interest are identified, including recusal from decisionmaking processes. Additionally, we recommend that staff involved in procurement be trained on these new policies to ensure proper implementation and adherence. Implementing these policies will help ensure compliance with federal requirements, promote transparency, and safeguard the integrity of the procurement process. Views of Responsible Official and Planned Corrective Action: See corrective action plan included in this report package.

Corrective Action Plan

Recommendation: We recommend that the Borough develop and implement comprehensive written procurement policies and conflict of interest policies that comply with the Uniform Guidance. Management’s Response: The Borough will research federal expenditure policies and determine the best way to move forward.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 497920 2023-004
    Significant Deficiency
  • 1074361 2023-003
    Material Weakness
  • 1074362 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $606,737
10.766 Community Facilities Loans and Grants $1,145