Finding Text
Assistance Listing Number(s): 21.027
Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury
Name of Pass-through Entity: County of Dane
Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR) Section 200.303 requires establishing and maintaining internal controls that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with the Federal statutes, regulations, and terms and conditions of the Federal award. Title 2 CFR Section 200.318(i) requires the maintenance of records sufficient to detail the history of procurement. These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.
Condition: Centro Hispano does not have written procurement procedures, did not document the procurement history, and did not use the proper method of procurement.
Cause: Centro Hispano obtained the contractor in 2022 and did not perform any procurement procedures prior to entering into the contract. During 2023, funding was obtained to cover the costs of this contract and nothing was indicated that the contractor was selected without proper procurement procedures for contracts over $250,000.
Effect or Potential Effect: Contract costs not supported by adequate documentation of procurement history using the correct procurement method could be disallowed.
Questioned Costs: $6,850,000
Repeat Finding: No.
Recommendation: Procurements should follow the required methods per Uniform Guidance and document the full procurement history. Procurement procedures should be designed, implemented, and written consistent with Uniform Guidance. Personnel responsible for procurement should be trained on Uniform Guidance requirements and Centro Hispano's written procurement procedures.
Views of Responsible Officials: Centro Hispano agrees with the finding and is establishing policies and procedures to provide adequate documentation of review and approval for procurement.