Finding Text
Assistance Listing, Federal Agency, and Program Name - 20.500, 20.507, 20.525, 20.526, U.S. Department of Transportation, Federal Transit Cluster
Federal Award Identification Number and Year - All, including COVID 19
Pass through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.320 provides standards for acceptable methods of procurement which includes the following required support for the contract price:
Informal procurement methods (micro purchases) may be awarded without submitting competitive price or rate quotations if the non Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents in files accordingly.
Small purchases require that price or rate quotations be obtained and documented to support the procurement decisions.
Formal procurement methods require documentation of sealed bids, proposals or rationale for the use of non competitive procurements such as single source and emergency procurements.
Condition - During our testing we identified five contracts that did not have adequate documentation to support the basis for the contract price.
Questioned Costs - $419,296
Identification of How Questioned Costs Were Computed - The sum of the expenditures incurred under the contracts for the five exceptions identified in our testing was used to calculated questioned costs.
Context - There was one contract subject to the micro purchase method of procurement that had no evidence to support whether the price was reasonable based on research, experience, purchase history or other factors.
There were two contracts subject to small purchasing procedures that had no evidence to support whether price or rate quotes were obtained.
There were two contracts subject to formal procurement methods that had no evidence to support whether sealed bids, proposals or noncompetitive procurements were used to support the contract price.
Cause and Effect - The Organization experienced turnover in personnel that resulted in the Authority being unable to locate documentation to support compliance for the five exceptions identified in our testing.
Recommendation - We recommend that internal controls be put in place to ensure that all procurements adhere to 2 CFR 200.320 and maintain documentation to support compliance and supervisory review.
Views of Responsible Officials and Corrective Action Plan - Implement a new internal controls checklist, and review process, along with procurement training for all management staff involved in the procurement process. In addition, TARTA will be moving to a new accounting ERP system in early 2025 that will automate the procurement workflow process to ensure proper approval and documentation has been obtained prior to procuring products and services, eliminating errors.