Finding 572166 (2023-001)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-07-29
Audit: 363273
Organization: Frist Art Museum (TN)
Auditor: Kraftcpas PLLC

AI Summary

  • Core Issue: FAM's procurement policy did not comply with federal guidelines, risking non-compliance with procurement standards.
  • Impacted Requirements: The policy failed to address the micropurchase threshold, which is essential under the Uniform Guidance.
  • Recommended Follow-Up: FAM should implement and adhere to a compliant procurement policy for all future purchases to avoid repeat findings.

Finding Text

Federal Program Information Funding Agency: U.S. Department of Treasury Federal ALN: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass Through Agency: Tennessee Arts Commission Criteria As required by the Uniform Guidance, procurement standards require non-federal entities to follow documented procurement procedures that are in compliance with the procurement standards in the federal guidelines. Condition During the period under audit, FAM had a procurement policy in place, but it did not comply with the procurement standards in the federal guidelines. Cause FAM did not develop a procurement policy that included compliance with the micropurchase threshold requirements and therefore did not have a procurement policy in place that met the requirements of the Uniform Guidance. Effect Purchases may occur that do not meet the procurement standards. Context For the year ending December 31, 2023, all of the expenditures charged to the grant were over the $10,000 micropurchase threshold. While certain agreements in effect during the year could be subject to the procurement requirements, most were in effect prior to the start of the grant period or are for services such as utilities or professional services not subject to the procurement requirements. No new agreements were entered into during the year ending December 31, 2023, that were charged against the grant. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit, 2022-002, which has been partially corrected. Auditor’s Recommendation FAM should ensure that the procurement policy subsequently implemented meets the procurement standards outlined in the Uniform Guidance, and should be followed for all purchases meeting the established thresholds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditor’s recommendation. In FY 2022, FAM encountered difficulties complying with this criterion because the grant was not awarded and under contract until over nine months after the grant period began. Long-standing vendor relationships were already in place and so costs were incurred prior to award knowledge. In FY 2023, FAM had already incurred costs before the FY 2022 Uniform Guidance audit brought to our attention that our procurement policy did not comply with federal guidelines. FAM has developed a procurement policy that meets the procurement standards outlined in the Uniform Guidance including established thresholds.

Corrective Action Plan

Procurement Auditor's Recommendation: FAM should ensure that the procurement policy subsequently implemented meets all the procurement standards outlined in the Uniform Guidance and should be followed for all purchases meeting the established thresholds. Corrective Action Taken: Management agrees with the auditor's recommendation. We encountered difficulties complying with this criterion because the grant was not awarded and under contract until over nine months after the grant period began. Longstanding vendor relationships were already in place and so costs were incurred prior to award knowledge. On a prospective basis, we will develop and adhere to a procurement policy that meets the procurement standards outlined in the Uniform Guidance including established thresholds. Corrective Action Completion Date: Subsequent to December 31, 2023, FAM has developed a procurement policy that complies with the Uniform Guidance requirements and will apply it to future grants with federal expenditures.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1148608 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $988,982
45.024 Promotion of the Arts Grants to Organizations and Individuals $45,000
45.025 Promotion of the Arts Partnership Agreements $15,000