Finding Text
Federal Program Name: Highway Planning and Construction Program
Federal Agency: U.S. Department of Transportation
Pass-through Entity: Indiana Department of Transportation
Federal Assistance Listing Title and Number: Highway Planning and Construction Program,
20.205
Award Year: 2014, 2015, 2018
Criteria or Specific Requirement: Under Uniform Guidance compliance requirements for
Procurement (2 CFR 200.318(i)), contract files must be sufficient to detail the history of
procurement. These records will include, but are not necessarily limited to, the following:
rationale for the method of procurement, selection of contract type, contractor selection or
rejection, and the basis for the contract price. In cases where competition was limited, such as
scenarios where specific qualifications and competence are required, the files should provide
evidence that the limitation on competition was justified.
Condition: The County entered into various professional services contracts for engineering and
consulting services for its highway grant programs but did not maintain appropriate
documentation to support its procurement decisions.
Questioned Costs: $0
Context: During our testing of procurement requirements, 3 out of 3 projects selected for testing
included contracts for engineering/consulting services. For 2 of the 3 contracts, the County
selected based on qualifications/competence established by the state Department of
Transportation rather than a formal RFP process but did not have appropriate documentation as
evidence of their basis for conclusion. The other contract tested was subject to an RFP process
but did not have appropriate documentation to support how the chosen firm was selected. Our
sample was not, and was not intended to be, statistically valid.
Effect: Contracts were approved without appropriate documentation to comply with Uniform
Guidance requirements.
Cause: Adequate supporting documentation on the procurements was not obtained or maintained
within project or vendor files due to oversight in administration of the program.
Repeat Finding: No
Recommendation: We recommend the County revisit controls over this compliance requirement
to ensure that appropriate documentation is gathered and retained within its procurement files to
support all Federally funded purchasing decisions.
Views of Responsible Officials and Planned Corrective Action: See corrective action plan
prepared by management attached.