Finding 57897 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-08-14

AI Summary

  • Core Issue: The Organization's procurement and conflict of interest policies lack essential elements required by federal standards.
  • Impacted Requirements: Compliance with procurement standards outlined in 2 CFR sections 200.318 through 200.326 is not met.
  • Recommended Follow-Up: Revise the procurement and conflict of interest policies to align with federal requirements to mitigate compliance risks.

Finding Text

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Laura Clark, the Director of Finance, is currently developing a procurement and related conflict of interest policy. These policies will be presented to the Board of Directors for approval at the July 2023 board meeting. Name of the contact person responsible for corrective action: Laura Clark, Director of Finance Planned completion date for corrective action plan: July 2023

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 57898 2022-002
    Significant Deficiency
  • 634339 2022-001
    Significant Deficiency
  • 634340 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.22M
16.575 Crime Victim Assistance $198,654
93.667 Social Services Block Grant $107,150
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $48,085
09.107 Technology Initiative Grant $31,912
14.218 Community Development Block Grants/entitlement Grants $2,500