Finding Text
Information on the Federal Program(s):
10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture
14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development
Compliance Requirements: Procurement.
Type of Finding: Material Noncompliance.
Criteria: 2 CFR § 200.318(c)(1) requires that the non-Federal entity 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.
Condition: We noted that the City did not have written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts in fiscal year 2022.
Cause: The City was not aware of the requirement to have written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts.
Effect: Failure to have written standards of conduct could result in noncompliance with Uniform Guidance requirements.
Questioned Costs: There are no questioned costs.
Recommendation: We recommend that the City develop written standards of conduct that include the requirements of 2 CFR § 200.318(c)(1).
Views of Responsible Officials and Planned Corrective Action: The City will develop written standards of conduct in that satisfy the requirements of 2 CFR § 200.318(c)(1).