Finding Text
Material weakness in internal controls over procurement and material noncompliance related to procurement
compliance requirements.
Federal Agency: U.S. Department of Treasury
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Number: HCS-23-AR-2113-058
Award Period: 3/21/21 – 12/31/26
Criteria:
2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity that has expended federal
awards to have written policies pertaining to its federal grants for procurement and that the history of each
procurement is documented in accordance with 2 CFR section 200.318(i).
Condition/Context for Evaluation:
The Organization received and utilized the federal award to pay for general contractor services for a construction
project that was ongoing at the time of the award. The Organization had entered the procurement of general
contractor service prior to receiving the federal award and in accordance with its existing procurement policy,
which included a competitive procurement process with a price analysis. However, there was not a procurement
policy in place that specifically covered the criteria required under the Uniform Guidance. As a result, the
Organization did not have a procurement policy and process in place that resulted in compliance with the Uniform
Guidance including the maintenance of records to detail the history of the procurement in accordance with 2 CFR
200.318(i).
Effect or Potential Effect:
As a result of not having adequate written procedures, a procurement was entered into that did not meet the
minimum Uniform Guidance procurement standards.
Questioned Costs:
Not applicable.
Repeat Finding:
Not applicable.
Recommendation:
We recommend that the Organization create written policies in accordance with and required by the Uniform
Guidance.