Finding 626725 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-08-10
Audit: 52895
Organization: City of Johnstown (PA)
Auditor: Wessel & Company

AI Summary

  • Core Issue: The City's procurement policy is not compliant with Uniform Guidance and lacks specific procurement methods and thresholds.
  • Impacted Requirements: Inadequate pre-award documentation and a non-centralized procurement process could lead to material control issues and improper vendor selections.
  • Recommended Follow-Up: The City should establish a compliant procurement policy and create a centralized process to ensure proper documentation and adherence to guidelines.

Finding Text

2022-003 ? Procurement Criteria: The City is responsible for establishing and maintaining a procurement policy which is compliant with the Uniform Guidance in 2 CFR 200.320. In addition, the City is responsible for maintaining adequate records relating to procurements. Condition: The City?s procurement policy lacks the specific methods of procurement to be followed and the respective thresholds for procurements using federal funds. Furthermore, there is not adequate pre-award documentation maintained relating to each of the City?s procurements. Cause: The City?s procurement policy was not adequately updated with necessary Uniform Guidance requirements. In addition, the City?s procurement process is not centralized and there is inadequate or missing pre-award documentation pertaining to the City?s various procurements. Effect: The condition above could result in material program and internal control issues relating to procurements whereby: appropriate methods of procurement may not be followed, debarred or suspended vendors or contractors could be awarded purchase orders or contracts, open and fair competition may not be achieved, etc. Context: Audit procedures noted that the procurement policy is inadequate and not in line with Uniform Guidance. Furthermore, audit procedures noted that there is no centralized process in place for tracking the City?s various procurements along with inadequate pre-award documentation. There was a total of $3,969,370 of expenditures relating to procurements during the year ended December 31, 2022; however, documentation was not deemed adequate to substantiate the procurements and whether they complied with Uniform Guidance. Questioned Costs: We questioned $3,969,370 of costs because this equaled the expenditures related to procurements during the year ended December 31, 2022. We reviewed the expenditures for the eight (8) projects with procurements during the year ended December 31, 2022 and determined that there was not appropriate pre-award documentation and an improper procurement policy that would permit the testing of procurements. Recommendation: We recommend that the City adopt a proper procurement policy that is in line with Uniform Guidance. We further recommend that the City develops a centralized procurement process whereby appropriate procurement type is documented along with the maintenance of proper pre-award documentation.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 50283 2022-003
    Material Weakness
  • 50284 2022-004
    Material Weakness
  • 626726 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $13.05M
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $254,370
16.710 Public Safety Partnership and Community Policing Grants $135,300
14.218 Community Development Block Grants/entitlement Grants $10,000
14.239 Home Investment Partnerships Program $6,884
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $4,691
14.218 Covid19 - Community Development Block Grants/entitlement Grants $4,596