Finding Text
2022-004 Significant Deficiency in Internal Controls over Compliance for Procurement, Suspension and Debarment Identification data: U.S. Department of Agriculture (USDA) Water and Waste Disposal Systems for Rural Communities ? grants, Assistance Listing No. 10.760 Criteria: Part 2 CFR 300.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Additionally, the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition and Context: The Village of Clearwater, Nebraska does not have a formal documented policy regarding procurement, suspension, and debarment transactions. Additionally, the Village does not have a written standards of conduct covering conflicts of interest and governing the performance of its employees engaged in the selection, award, and administration of contracts. Cause: A breakdown in the Village?s internal controls over procurement, suspension and debarment did not allow the Village to comply with the standards. Effect or potential effect: The control deficiency is a significant deficiency that may prevent the Village from complying with the procurement, suspension, and debarment requirements of the award agreements. Recommendation: The Village?s management and Board should develop formal written policies and procedures for procurement, suspension and debarment transactions. Additionally, the Village should adopt written standards of conduct covering conflicts of interest. Views of Responsible Officials: The Village of Clearwater, Nebraska?s management and Board will work on developing formal written procedures for procurement, suspension and debarment transactions. Additionally, the Village will adopt written standards of conduct covering conflicts of interest.