Finding Text
U.S. Department of the Treasury
Passed through Lancaster County, Nebraska
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
AL #21.027
Criteria: 2 CFR 200.318 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local law regulations, provided that the procurements conform to applicable federal law and standards.
Condition: The Organization does not have a formalized procurement policy that conforms to applicable standards under Uniform Guidance. Additionally, the Organization did not follow procurement policies when obtaining bids for contracts.
Cause: Due to grant timing restraints, the Organization did not follow proper procurement procedures for obtaining bids for contracts under the Uniform Guidance. Adequate internal controls were not in place to ensure a documented policy in compliance with procurement
requirements was in place.
Effect: The Organization did not have proper procedures to ensure its procurement policies were updated to conform to the requirements identified in Uniform Guidance. Additionally, the Organization did not follow proper procurement procedures.
Questioned Costs: None
Context/Sampling: One contract over the small purchase threshold and one contract over the simplified acquisition threshold were selected for testing. Both contracts did not follow procurement compliance requirements including obtaining competitive bids or documentation to support the bidding process. These transactions totaled $749,431 of $760,284 costs tested.
Repeat Finding from Prior Year: No
Recommendation: Management should implement a formal procurement policy using the guidance of 2 CFR 200.317 – 200.327. Additionally, management should follow this policy when procuring services or property.
Views of Responsible Officials: Management agrees with this finding.