Finding 524376 (2023-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-02-24

AI Summary

  • Core Issue: The Corporation lacks written procurement policies for contract management.
  • Impacted Requirements: This violates 2 CFR 200, Subpart D, which mandates standards of conduct for procurement.
  • Recommended Follow-Up: Implement a Corrective Action Plan to establish necessary internal controls and written policies.

Finding Text

Procurement Policies (Repeat of 2022-003) Criteria: Section 2 of the Code of Federal Regulations (CFR), Part 200, Subpart D, includes the procurement standards which require written standards of conduct for an entity governing the actions of its employees engaged in the selection, award, and administration of contracts. Condition: The Corporation does not have written procurement policies governing the selection, award, and administration of contracts. Cause: The Corporation does not have sufficient internal controls to ensure they are in compliance with the requirements of federal programs. Effect: The Corporation is not in compliance with 2 CFR 200, Subpart D which could lead to inappropriate selection, award, or administration of contracts and federal program noncompliance. Response: See Corrective Action Plan.

Corrective Action Plan

We concur with the finding and agree that we should have written procurement policies to comply with 2 CFR 200 Subpart D. We have developed and implemented comprehensive written policies that align with the provisions of 2 CFR 200 Subpart D and other relevant sections. These policies have been incorporated into the organization's accounting procedures and policy manual. Additionally, a specific procurement policy has been created and implemented as a component of the broader financial policy document. Procedures were implement in 1st Quarter 2024 and will be applied indefinitely.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1100818 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $1.18M
14.889 Choice Neighborhoods Implementation Grants $687,275