Finding Text
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: The Salvation Army of Dane County Criteria or Specific Requirement: 2 CFR section 200.313(i) requires non-federal entities to maintain records sufficient to detail the history of procurement, including, but not necessarily limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: YWCA?s internal controls over review of procurement methods, rationale, and decisions, were not properly documented. Cause: Written policies and procedures for procurement did not include who was responsible, what documentation is required, and retention of the control documentation for procurement methods, rationale, and decisions. In addition, YWCA experienced turnover in the CFO position, which is responsible for reviewing and approving procurement methods, rationale, and decisions. Effect or Potential Effect: Contracts entered into may be disallowed. Repeat Finding: No. Recommendation: We recommend written policies and procedures over procurement to be established to clearly document who is responsible for reviewing, what is to be reviewed, and how and where to document the review of procurement methods, rationale, and decisions. Views of Responsible Officials: YWCA agrees with the finding and is establishing policies and procedures to provide for documentation and review of procurement methods, rationale, and decisions. This is expected to be completed by September 2023.