Finding Text
U.S. Department of Treasury, Passed Through Nebraska Department of Public Health COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria: The design or operation of the Organization’s internal controls over compliance should ensure that purchase transactions comply with Uniform Guidance requirements related to the Procurement, Suspension, and Debarment compliance requirement. Condition: The Organization’s purchasing policies and controls do not comply with the Uniform Guidance requirements related to the Procurement, Suspension, and Debarment compliance requirement. Cause: The Organization’s purchasing policies were developed prior to the Organization’s participation in programs funded by Federal grants, and were not updated to include a process to verify that vendors meeting certain purchase thresholds were not suspended or debarred from receiving federal funds. Effect: Purchases made by the Organization with grant funds may not be in compliance with the procurement compliance requirements of the Uniform Guidance. The Organization may have used vendors who are suspended or debarred from receiving federal funds. Questioned Costs: None reported. Context: We selected a sample of purchases made by the Organization subject to the procurement compliance requirement, and noted that the Organization did not have the internal controls in place to review whether the vendors were suspended or debarred from receiving federal funds, as the Organization's procurement policies did not include all elements required by Uniform Guidance. Repeat Finding From Prior Year: No Recommendation: The Organization’s purchasing policies should be reviewed and updated to ensure compliance with the Procurement, Suspension, and Debarment compliance requirements of the Uniform Guidance. Views of Responsible Individuals: Management acknowledges that existing purchasing policies and controls were not reviewed or updated to ensure compliance with Uniform Guidance requirements.