Finding Text
U.S. Department of Treasury
Federal Financial Assistance Listing 21.027
All Awards
State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required.
Condition: In our testing of procurement, suspension and debarment it was identified that the Organization did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities.
Questioned Costs: None reported.
Context/Sampling: Overall procurement policy.
Repeat Finding from Prior Year: No.
Recommendation: We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management agrees with the finding.