Finding Text
U.S. Department of Housing and Urban Development
Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina
Program Name: Emergency Solutions Grant
Federal Assistance Listing Number: 14.231
U.S. Department of Treasury
Pass-through Entity: Mecklenburg County, North Carolina
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Significant Deficiency and Nonmaterial Noncompliance – Procurement
Finding 2024-003
Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-federal entity must have and use documented procurement procedures, consistent with Uniform Grant Guidance Title 2 CFR Section 200.318 for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to a suspended or debarred party listed on the System for Award Management.
Condition: There was one (1) instance in which a sole source provider was utilized rather than going through the bidding process that was not documented in line with the Uniform Grant Guidance requirements. There was another vendor where only one informal quote was obtained and the rationale for their selection was not documented. The same vendor was also not verified as not being on the suspended or debarred party list on the System for Award Management prior to procuring their services.
Questioned Costs: None noted.
Effect: By not having sufficient documentation, the Organization may not be able to evidence compliance with Uniform Grant Guidance and could have improperly contracted with a vendor.
Cause: The Organization did not obtain quotes from more than one vendor nor document sole source justification for the contracts tested.
Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance and ensure proper documentation of the procurement process for all vendors utilized with federal funding.
Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.