Finding Text
SD 2022-006 Subrecipient Procurement Policy Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR Part 180 prohibits award recipients from entering into covered transactions with vendors who are suspended or debarred. Further, 2 CFR 200.320 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Policies and procedures at subrecipient organizations should ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Condition: Subrecipients are required to have procurement policies which ensure competitive procurement and use vendors who are not suspended or debarred for grant-funded expenditures. Cause: The Organization has not developed a process to monitor this requirement for subrecipients. Effect: The Organization may reimburse subrecipients for transactions which did not comply with competitive procurement requirements or were made with suspended or debarred vendors. Questioned Costs: None Perspective: The Organization has competitive procurement procedures and verifies vendors are in good-standing for their grant-funded expenses. Procurement policies at subrecipients have not been required to be provided or evaluated. Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We addressed the procurement policies with our existing subcontractors during their fiscal year 21-22 Monitoring visits in May, 2022. We added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. All new sub-recipient contracts that went into effect July 1, 2022 made the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.