FAC Explorer

Finding 93897 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-28
Audit: 90093
Organization: Town of Easton (the Easton Utilities Commission) (MD)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The Commission lacks adequate documented procurement policies, leading to a significant deficiency in compliance with federal standards.
  • Impacted Requirements: Non-compliance with 2CFR § 200.318(a) and related procurement standards (§§ 200.317-200.327) for federal awards.
  • Recommended Follow-Up: Establish and document procurement policies that align with federal requirements to ensure compliance.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 ? July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2CFR ? 200.318(a), non-Federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Questioned Costs: None Condition/Context: The Commission?s procurement policy for federal expenditures is not in accordance with ?? 200.317 through 200.327. Cause/Effect: The Commission does not have sufficient documented policies and procedures over procurement to ensure federal procurement requirements are met. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will adopt a written procurement policy in accordance with the federal requirements. Since the inception of the Rural eConnectivity program, the Commission has followed the Town of Easton Charter Article IV, Section 2(e) when contracting with third party vendors. The Commission now recognizes compliance with the Charter does not satisfy the necessity for a separate procurement policy to fulfill federal requirements. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 93898 2022-002
    Significant Deficiency
  • 670339 2022-001
    Significant Deficiency
  • 670340 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.752 Rural Econnectivity Pilot Program (b, E) $1.61M
21.027 Coronavirus State and Local Fiscal Recovery Funds $229,798
32.002 Universal Service Fund - High Cost $15,754