Finding 626324 (2022-001)

2022-001 ? Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Treasury ? Coronavirus State and Local Fiscal Recovery Funds (CFDA# 21.027) Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the government. Such procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000. Also, recipients of federal awards are required to ensure that federal procurement standards are followed for any purchases over the federal micropurchase threshold. 2 CFR 200.320 requires that these purchases must adhere to one of the allowable procurement methods (sealed bids, competitive proposals, noncompetitive procurement) and maintain documentation of this procurement decision. Condition. The County charged costs for multiple vendors to federal grants that they determined fell under noncompetitive procurement in accordance with 2 CFR 200.320. However, documentation was not obtained to support such determinations. Cause. This condition is a result of the County not properly documenting procurement methodology. Effect. As a result of this condition, several vendors paid with federal funding appeared to be procured in a manner not in accordance with federal regulations. Questioned Costs. No costs were questioned as a result of this finding. Recommendation. We recommend that the County implement a policy to address noncompetitive procurement circumstances. View of Responsible Officials. The County agrees that a policy needs to be implemented to address noncompetitive procurement circumstances. Responsible Officials. Finance Director Estimated Completion Date. December 31, 2023