Finding Text
AL number: 10.561
AL title: Supplemental Nutrition Assistance Program
Award term: October 29, 2021 through September 30, 2024
Name of federal
agency:
U.S. Department of Agriculture
Name of pass-through
entity:
Colorado Department of Human Services
Repeat finding: Yes - 2022-002 & 2022-003
Criteria: The Code of Federal Regulations 2 CFR 200.3 l 8(a) states, "the non-
Federal entity must have and use document procurement procedures,
consistent with State, local, and tribal laws and regulations and the
standards of this section, for the acquisition of property or services
required under a Federal award or subaward."
In addition, per the Code of Federal Regulations 2 CFR 200.214, non-
Federal entities are subject to the non-procurement debarment and
suspension regulations. The regulations restrict awards, subawards, and
contracts with certain- parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in Federal assistance
programs or activities.
Condition: During our testing, we noted the Organization had not adopted a procurement
policy and no procurement procedures were performed in selecting contractors.
Cause: Procurement policies and procedures were not adopted by the Organization.
Possible effect: The Organization may not have received a competitive bid for services, and may
have engaged a suspended or debarred contractor.
Questioned cost: None
Recommendation: We recommend the Organization implement necessary internal controls to ensure
a competitive bid process is performed and all vendors are reviewed for
suspension and debarment, prior to entering into contracts utilizing federal
awards. These internal controls should also include a conflict-of- interest clause
with all vendors within contract language.
Views of responsible
officials:
Management recruited a procurement officer in December 2024 to design and
implement best practice procurement processes effective the first quarter 2025.
Procurement policies will ensure full compliance with Federal and State
requirements. Procurement policies will incorporate clearly defined procedures
around all contractors ensuring appropriate selection processes and contractual
terms.
Anticipated completion date: March 31, 2025.