Finding Text
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Procurement, Suspension and Debarment
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal control over federal awards that provides reasonable assurance that the Foundation is
managing the federal award in compliance with federal statutes, regulations and terms and
conditions of the federal award. The non‐Federal entity’s documented procurement procedures
must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which
also requires documentation to be retained to detail the history of procurements. In addition, as
outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or
is otherwise excluded from the central contractor registry.
Condition: The Foundation did not retain documentation to support performance a price
analysis nor provide the opportunity for open competition. Additionally, the Foundation did not
review for suspension or debarment and required contract provisions were not followed.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of procurement.
Effect: Improper expenses may be paid and charged to the federal program and covered
transactions could be potentially entered into with suspended or debarred parties.
Questioned Costs: Questioned costs were unable to be determined.
Context: A nonstatistical sample of 12 transactions out of 60 total transactions were selected for
testing totaling $148,605 of $275,567 procurement expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation follow designed control processes which
includes performing required procurement procedures and maintaining within the procurement
file documentation of a review to ensure the party to the covered transaction is not suspended
or debarred.
Views of Responsible Officials: Management agrees with the finding.