Finding 555169 (2024-001)

2024-001 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Significant Deficiency in Internal Control Over Compliance – Appropriate Internal Control Structure Related to Compliance Requirements I. Procurement and Suspension and Debarment Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that CICP must, among other things, “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)”. Condition and Context: We noted CICP did not complete their procurement checklist timely for one specific vendor, in accordance with their written policies. The procurement checklist is CICP’s key control for monitoring procurement and suspension and debarment of vendors. The vendor relationship was an existing relationship, but the vendor had not previously been used for any activities related to federal awards. CICP had other written documentation which provided evidence they followed their procurement process; however, no written documentation was maintained indicating suspension or debarment was reviewed prior to using the vendor for activities related to the federal award. Cause and Effect: Not completing the procurement checklist timely could result in noncompliance related to procurement and suspension and debarment. Recommendation: We recommend the procurement checklist be completed in line with the written policies of CICP. Views of Responsible Officials and Planned Corrective Action: CICP agrees with the recommendation and it was implemented effective 2/14/2025.