Finding 620602 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-08-08
Audit: 46079
Organization: City of Appleton (WI)

AI Summary

  • Core Issue: The City failed to follow procurement controls, leading to non-compliance with federal requirements.
  • Impacted Requirements: 2 CFR 200.320(a)(2)(ii) mandates proper procurement procedures and verification of entities involved in transactions.
  • Recommended Follow-Up: The City should review and update its procurement policies to align with 2 CFR 200 for all federal grants.

Finding Text

2022-001 Procurement Federal Agency: U.S. Department of Treasury Federal Program Name: American Rescue Plan Act Assistance Listing Number: 21.027 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The City did not follow controls related to ensuring procurement policies were followed. Questioned Costs None. Context While performing compliance procedures, it was noted that the City did not follow adopted policies for procurement. Cause Items purchased through procurement transactions were individually insignificant thus City believed procurement was not applicable. However, when applying the micro purchase threshold, a nonfederal entity should note the threshold applies to the aggregate purchase amount rather than the cost of individual items. Effect The City is not in compliance with procurement requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding No. Recommendation We recommend the City review and update procurement policies for the entire City to ensure they meet the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials There is no disagreement with the finding.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 44156 2022-002
    Material Weakness
  • 44157 2022-002
    Material Weakness
  • 44158 2022-002
    Material Weakness
  • 44159 2022-001
    Material Weakness
  • 44160 2022-001
    Material Weakness
  • 44161 2022-001
    Material Weakness
  • 44162 2022-001
    Material Weakness
  • 620598 2022-002
    Material Weakness
  • 620599 2022-002
    Material Weakness
  • 620600 2022-002
    Material Weakness
  • 620601 2022-001
    Material Weakness
  • 620603 2022-001
    Material Weakness
  • 620604 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit_formula Grants $1.25M
14.218 Community Development Block Grants/entitlement Grants $598,767
14.231 Emergency Solutions Grant Program $415,787
14.235 Supportive Housing Program $331,979
21.027 Coronavirus State and Local Fiscal Recovery Funds $225,617
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $217,973
93.069 Public Health Emergency Preparedness $80,688
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $44,571
93.994 Maternal and Child Health Services Block Grant to the States $31,757
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $31,100
93.539 Pphf Capacity Building Assistance to Strengthen Public Health Immunization Infrastructure and Performance Financed in Part by Prevention and Public Health Funds $24,192
93.268 Immunization Cooperative Agreements $11,752
93.991 Preventive Health and Health Services Block Grant $11,029
16.607 Bulletproof Vest Partnership Program $8,591
20.600 State and Community Highway Safety $7,803
16.738 Edward Byrne Memorial Justice Assistance Grant Program $5,128
93.566 Refugee and Entrant Assistance_state Administered Programs $67