Finding 51631 (2022-006)

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Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-01-05
Audit: 43508
Organization: City of Plentywood (MT)

AI Summary

  • Core Issue: The city lacks a formal, written conflict of interest policy and procurement manual as required by federal standards.
  • Impacted Requirements: This noncompliance with 2 CFR sections 200.318 through 200.327 affects the integrity of contract selection and administration.
  • Recommended Follow-Up: The city should create a comprehensive procurement manual to ensure compliance and address the identified gaps.

Finding Text

FEDERAL PROCUREMENT Criteria: 2 CFR sections 200.318 through 200.327 govern procurement standards for federal programs. Per these standards, a non-federal entity (the city) must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Also, no employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition: The city does not have a formal, written conflict of interest policy or procurement manual as required by 2 CFR section 200.318. Cause: Responsible officials were unaware of the requirement. Effect: Noncompliance with federal procurement standards. Recommendation: The city should develop a formal procurement manual that contains all elements necessary to comply with 2 CFR sections 200.318 through 200.327. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.

Corrective Action Plan

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the bestowal of federally procured recovery funds based upon relationship rather than merit. See, Mont. Code Ann. ? 2-2-301. To that end, the City shall draft and pass via majority vote of City Council Members a resolution to address this issue which complies with State and Federal regulation of said funds. Said resolution will be passed in 2023 prior to the conclusion of the City's fiscal year. Proposed Completion Date: Fiscal Year 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 51630 2022-005
    Material Weakness Repeat
  • 51632 2022-005
    Material Weakness Repeat
  • 51633 2022-006
    -
  • 628072 2022-005
    Material Weakness Repeat
  • 628073 2022-006
    -
  • 628074 2022-005
    Material Weakness Repeat
  • 628075 2022-006
    -

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.64M
66.458 Capitalization Grants for Clean Water State Revolving Funds $110,445