Finding 529651 (2023-006)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2025-03-24

AI Summary

  • Core Issue: The Town's internal controls over procurement are not working properly, leading to missing documentation for compliance.
  • Impacted Requirements: The lack of documentation violates 2 CFR 200 and procurement standards under 42 USC, risking improper purchases.
  • Recommended Follow-Up: The Town needs to establish a reliable system to ensure procurement policies are effectively implemented and monitored.

Finding Text

Criteria: In accordance with 2 CFR 200, management should have an adequate system of internal control procedures in place to ensure that applicants have all required documentation in their file. In accordance with 42 USC Section 802(c) and 803(c) and Treasury’s Interim Final Rule and Final Rule, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. Condition: The Town’s internal controls over procurement are not functioning as intended. Context: Of the 19 procurements during the current year valued at $2,799,733, we examined 4 (valued at $1,121,990) and determined that 4 (100% valued at $1,121,990) did not have documentation to verify that internal controls and compliance with procurement guidelines were being followed. The proper procurement documentation was not kept on file as required by procurement guidelines for use of COVID 19 – Coronavirus State and Local Fiscal Recovery funding. Effect: Purchases may be made without the proper procurement procedures being followed. Cause: Due to staff turnover at the Town, there were instances where proper procurement documentation was not kept on file. Questioned Cost: In accordance with 2 CFR 200, auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. The sample results identified $1,121,990 in known questioned costs. Recommendation: The Town should have a system in place to ensure that the procurement policies are implemented and functioning as intended. Views of Responsible Officials and Planned Corrective Actions: The Town agrees with this finding. Please refer to the Corrective Action Plan section of this report.

Corrective Action Plan

Finding: 2023-006 Name of Contact Person: Stephen Ford, Finance Director Corrective Action: The Town seeks to make the procurement process fair, open, and guided by a legal procurement process and related procedures. In May 2023, a new procurement policy and procedures was developed and adopted by Town Council. Prior to the new policy, the prior guiding document was flawed, unclear, and sometimes vague. The new policy addressed those deficiencies and the new policy will be used in subsequent years. Also, in regards to the some major purchases, the Town had to address some purchases that availability, accessibility to services (sole source), extension of services (labor and need), and Council oversight. However management and Town Council confirms the need for safeguarding and adhering to the procurement policy, and has implemented training among staff as well as requiring general contractor oversight. Proposed Completion Date: The Town will implement the above procedure immediately.

Categories

Questioned Costs Procurement, Suspension & Debarment HUD Housing Programs

Other Findings in this Audit

  • 529652 2023-006
    Material Weakness
  • 1106093 2023-006
    Material Weakness
  • 1106094 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.80M
97.041 National Dam Safety Program $158,778