Finding Text
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-Federal entity to maintain records sufficient to detail the history of procurement. In the case of an emergency or sole source purchase, proper documentation of this must be maintained. Condition: Emergency purchases for Federal awards were not adequately documented to support the lack of traditional procurement process being required. Questioned costs: None Context: In the testing of 6 of 10 procurement transactions, the County did not maintain appropriate documentation to support they were emergency purchases. Cause: With new federal funding opportunities arising due to the COVID-19 pandemic, and new guidance related to those grants, departmental grant personnel were not aware of these requirements. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat Finding: This is a repeat finding of part of prior year finding 2021-004 Recommendation: We recommend updating written procurement policies and ensuring procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and proper documentation is maintained. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Grant Guidance requirements that should be completed when making purchases and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.