Finding Text
2022-001 Methods of Procurement Federal Agency: United States Department of Treasury Federal Program Name: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLT-8694, 2021 Award Period: March 3, 2021 to December 31, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of federal procurement guidelines. US Code ? 200.320 states that the non-Federal entity must have and use documented procurement procedures, consistent with the standards of ? 200.320 and ?? 200.317, 200.318, and 200.319 for any of the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition: The County entered into a noncompetitive procurement contract with a vendor under specific circumstances for an emergency procurement. The County did not document the justification or approval of the noncompetitive emergency procurement. The County?s internal procurement policies state that deviations from standard purchasing procedures must be authorized and all such deviations will be documented and all emergency purchases shall be in a report to the Board of County Commissioners at its next regular Commission meeting. Context: One of five procurement contracts tested did not contain appropriate documentation supporting federal procurement requirements. Cause: The County did not follow their procurement policies and procedures to properly document the justification and approval of an emergency procurement transaction that was made using federal funding and requirements for noncompetitive emergency procurements. Effect: By not following federal regulations and the County?s procurement policy, the County could improperly enter into a contract that violates the requirements of CFR ? 200.320. Repeat Finding: No Recommendation: We recommend that the County review their policies and procedures to ensure that they are operating in a manner that follows federal procurement requirements and the County?s procurement policy. The creation and use of a standard procurement checklist would assist the County in documenting all requirements for each procurement that is entered into. Views of Responsible Officials: The Finance Department will work with County Management and Board Departments to ensure familiarity and understanding of the County?s procurement policies and procedures. Additionally, the County is working towards the implementation of a financial system which will improve the controls in place to help ensure compliance with procurement requirements. The Finance Department is also working on a financial policies document and will would with County Manager on a review of the County?s procurement policy.