Finding Text
2024 – 002
Federal Agency: U.S. Department of Justice
Federal Program Title: Crime Victim Assistance
Federal Assistance Listing Number: 16.575
Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs
Pass-Through Number(s): A-CVS-2024-AMS-077
Award Period: 10/01/2023 to 09/30/2025
Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: The Organization did not have a written procurement policy in accordance with Uniform Guidance for a portion of the year. In addition, during our testing, we noted the Organization did not apply the proper procurement procedures for two vendors as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance.
Questioned Costs: Unknown
Context: Two out of the two procurement selections did not have procurement procedures followed.
Cause: Vendors were procured prior to the implementation of a formal procurement policy; therefore, proper documentation was not retained as of the procurement date.
Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards.
Repeat Finding: This is a repeat finding.
Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG.
Views of Responsible Officials and Planned Corrective Actions: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements.