Finding Text
2022-006 Federal Agency: Department of the Treasury and Federal Communications Commission Federal Program Name: American Rescue Plan Act and Emergency Connectivity Fund Program Assistance Listing Number: 21.027 and 32.009 Federal Award Identification Number and Year: 12060-OPM20600-29669 and ECF202108044 Pass-Through Agency: Office of Policy and Management Pass-Through Number(s): N/A Award Period: 7/1/2021 - 6/30/2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of suspension, and debarment. Condition: The Town must update their policies to indicate they will verify that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Questioned costs: None noted. Context: Although the Town did not have a policy in place in conformity with the federal uniform guidance criteria, the Town did follow Uniform Guidance and was in compliance with the major program. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Town is at risk for noncompliance as it related to suspension & debarment. Repeat Finding: N/A - First year audited as a major program. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding and is in process of developing a formal policy.