Finding Text
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324 and 2 CFR 180.220) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred. These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Condition: Procurement methods for certain federal award purchases were not adequately documented and the County did not verify the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: None Context: 3 of 5 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation. Cause: Lack of documentation retained over procurement rationale or cost analysis and lack of knowledge on suspension and debarment policy. Effect: Purchases are not properly documented to meet the Federal procurement requirements. CLA was able to determine the vendors were not suspended or debarred. Repeat Finding: This finding is a repeat of a finding in the prior year on a different program. Prior year finding number was 2021-003. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.