Finding Text
2023-001 PROCUREMENT
Federal Program Information: Federal Transit Cluster 20.507
Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.318(h) states “the non-federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources.”
Condition: For all of the contracts selected for testing, documentation could not be located to support that the Authority verified the entity it planned to enter into a covered transaction with was not debarred, suspended, or otherwise excluded.
Questioned Costs: Unknown
Context: Total federal expenditures for the Federal Transit Cluster were $10,065,940 for the year ended June 30, 2023.
Cause: The Authority did not retain adequate documentation showing entities were not debarred, suspended, or otherwise excluded.
Effect: The Authority is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award.
Recommendation: We recommend that the Authority implement controls to ensure that entities are not debarred, suspended, or otherwise excluded and that adequate supporting documentation is maintained.
Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.