Finding Text
Finding 2022-001 Department of Treasury Assistance Listing Number 21.027 ? Access to Justice Initiative Civil Legal Services Program and Civil Legal Counsel Projects Program Significant Deficiency in Compliance over Procurement Repeat Finding: No Criteria: According to 2 CFR Part 180 and 5532, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition/Context: For one of four items in our procurement sample, DCBF could not provide documentation summarizing its justification for the rationale of the method of procurement and therefore, we were not able to verify that the procurement method was appropriate. Cause: DCBF did not follow its procurement policies related to the documentation of sole source vendors in accordance with Uniform Guidance. Effect: DCBF was not in compliance with the procurement documentation requirements of its Federal grant agreement and the Uniform Guidance. As a result, DCBF could have entered into contracts with vendors that either did not meet the criteria to be sole source providers or that were suspended, debarred or otherwise excluded.Questioned costs: None. Recommendation: DCBF should continue to follow its procurement policy in accordance with Federal grant agreement. Views of responsible officials: Management concurs with and will implement the recommendation. See Corrective Action Plan.