Finding 573137 (2024-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-08
Audit: 363951
Organization: Mienergy Cooperative (MN)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The procurement policy lacks clear dollar thresholds for different procurement methods.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303(a) and 2 CFR 200.318 regarding internal controls and documented procurement policies.
  • Recommended Follow-Up: Review and update the procurement policy to include dollar thresholds and ensure all contracts have required provisions.

Finding Text

Department of Homeland Security, Iowa Department of Homeland Security and Emergency Management, Federal Financial Assistance Listing 97.039, DR-4457-IA-0040 Hazard Mitigation Grant Program Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal awards that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards in sections 200.317 through 200.327. Condition: The cooperative’s procurement policy had not identified the dollar thresholds of procurement within the methods of procurement. In addition, one contract selected for testing was missing one of the required contract provisions. Cause: The cooperative’s procurement policy is very thorough and identifies the methods of procurement, however, management had not identified the thresholds of procurement included within the policy. Effect: The Cooperative’s policy was missing required information Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 7 transactions out of 29 transactions were selected for testing, which accounted for $1,134,758 of $3,548,469 federal program expenditures. Repeat Finding form Prior Year: No Recommendation: We recommend the Cooperative review their procurement policy to ensure it includes the dollar thresholds for each of the procurement methods. In addition, we suggest the Cooperative review their contracts to ensure it includes all the required contract provisions. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Department of Homeland Security and Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: The Cooperative's procurement policy had not identified the dollar thresholds of procurement within the methods of procurement. In addition, one contract selected for testing was missing one of the required contract provisions. Corrective Action Plan: The Cooperative is working with our attorney to update the procurement policy to include the dollar thresholds of each method of procurement. We will update the procurement policy after acceptable changes are made. Responsible Individuals: Shelly Hove, CFO Anticipated Completion Date: September 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 573136 2024-002
    Material Weakness
  • 1149578 2024-002
    Material Weakness
  • 1149579 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.039 Hazard Mitigation Grant $3.19M
10.752 Rural Econnectivity Pilot Program $281,667
10.855 Distance Learning and Telemedicine Loans and Grants $49,444