Finding 565390 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-19

AI Summary

  • Core Issue: CSC failed to maintain proper documentation for procurement transactions, lacking evidence of competitive bidding for four out of five transactions tested.
  • Impacted Requirements: This finding relates to the Uniform Grant Guidance, which mandates detailed records for procurement processes, including rationale for vendor selection and contract pricing.
  • Recommended Follow-Up: CSC should consistently apply updated procurement policies to ensure compliance and minimize risks of misstatements, particularly for transactions exceeding $10,000.

Finding Text

2024-001 Procurement Federal Agency: U.S. and Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Assistance Listing Number: 21.027 Award Period: October 1, 2023 to September 30, 2024 • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria: Uniform Grant Guidance requires UG §200.318 General procurement standards requires the non-Federal entity must maintain records 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. Condition: During our testing, we noted that CSC did not maintain support for procurement transactions exceeding the threshold. These transactions were not competitively bid, and the rationale for vendor selection was not documented. Questioned Costs: None Context: For four out of five procurement transactions tested, we noted that documentation related does not have evidence showing that proper competitive bidding was performed. Cause: The policies and procedures surrounding the procurement transaction tested was not consistently followed as designed. Effect: We noted no instance of noncompliance with the provisions of procurement; however, the lack of effective internal controls over this compliance requirement provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that CSC ensure consistent application of its policies and procedures to minimize the risk of intentional and unintentional misstatements in the normal course of business. Views of Responsible Officials of the Auditee: Explanation of disagreement with audit finding. CSC disagrees with the classification of 2004-001 as a significant finding rather than receiving management recommendations on improving our procedures from the auditors because there was only one item where CSC could not retrieve the proof that at least three bids were sought prior to the signing of the contract. CSC does not consider the three other items that the auditors flagged as clear procurements because two of the items were disbursements of funds on behalf of clients for vocational education that those clients had already signed up for and were preapproved by the funder in question. CSC had no option but to disburse funds for those educational activities. The rational for the disbursements can be found in the grant agreement. Similarly in the case of the third item, CSC had to disburse funds based on the criteria provided by the grantor and the grantor approved the transaction prior to its signing. These are grey areas that deserve no more than formal management recommendations. Regardless, based on the results of the audit, CSC has updated its procurement policy for grant-related purchases to align with federal requirements by increasing the spending threshold that requires obtaining bids from at least three vendors or service providers from $5,000 to $10,000. Action Taken in Response to Finding: CSC’s updated procurement policy states in part that price or rate quotations must be obtained from an adequate number of qualified sources for the procurement of services, supplies, or other property that cost more than $10,000 but no more than $250,000. Generally, a minimum of three bids should be obtained and documented. Procurements over $250,000 require the use of Competitive Proposals.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 565389 2024-001
    Significant Deficiency
  • 565391 2024-002
    Significant Deficiency
  • 565392 2024-002
    Significant Deficiency
  • 1141831 2024-001
    Significant Deficiency
  • 1141832 2024-001
    Significant Deficiency
  • 1141833 2024-002
    Significant Deficiency
  • 1141834 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.818 Children Exposed to Violence $294,386
21.027 Coronavirus State and Local Fiscal Recovery Funds $280,980
93.590 Community-Based Child Abuse Prevention Grants $150,000
93.569 Community Services Block Grant $139,215
84.425 Education Stabilization Fund $100,000
93.645 Stephanie Tubbs Jones Child Welfare Services Program $32,000