Finding Text
2022 – 005 Procurement/Suspension & Debarment
Federal agency: U.S. Treasury Department
Federal program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
FALN Number: 21.027
Award Period: March 2021 through December 2024
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Condition: During our testing, we noted the County did not have internal controls designed to ensure compliance with federal procurement and suspension and debarment requirements.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The County should have internal controls designed to ensure compliance with those provisions. The County is required to have documentation and follow procurement requirements including obtaining price or rate quotations from an adequate number of qualified sources for small purchases and sealed bids. The County is also required to verify an entity is not suspended or debarred.
Questioned costs: None
Context: During our testing, it was noted that the County did not follow procurement requirements for 2 of 3 small purchases and 1 of 1 sealed bids tested. The County did not follow suspension and debarment requirements.
Cause: The County does not have a written procurement policy in place that clearly addresses compliance with federal grant requirements per the Uniform Guidance.
Effect: The County’s noncompliance with procurement and suspension and debarment requirements could lead to a negative impact on future funding for the County.
Repeat finding: No
Recommendation: We recommend the County review the federal procurement requirements outlined in the federal Uniform Guidance and create a written policy to address federal compliance requirements. Additionally, we recommend a designated individual at the County ensures purchases made with federal grant funding comply with federal procurement requirements by type of procurement (micropurchase, small purchase, sole-source, etc.) and also suspension and debarment requirements.