Finding Text
Procurement (Significant Deficiency) and Compliance
Federal Agency: U.S. Department of Homeland Security
Program Title: Emergency Food & Shelter National Board Program (“EFSP”)
Assistance Listing Number: 97.024
Federal Award Source: Pass-through funding
Pass-Through Entity: Pima County
Pass-Through Identifying Number: CT-GMI-21-452
Criteria – Section §200.320 of the Uniform Guidance requires that when the value of the procurement for property or services under a Federal financial assistance award exceeds the Simplified Acquisition Threshold, a formal procurement method is required, such as a sealed bid or proposal. In addition, these formal procurement methods require public advertising.
Condition – During our audit of the procurement requirements for the EFSP program, we noted the Organization utilized a vendor who in total was paid more than the Simplified Acquisition Threshold; however, the Organization did not utilize a formal procurement method in selecting this vendor as required by their policies and the Uniform Guidance.
Cause – The finding appears to be the result of an immediate need to obtain services and an oversight to subsequently conduct a formal procurement method.
Effect and Context – By not adhering to a formal procurement method, the Organization may or may not have chosen the best vendor to provide the services. There was only one vendor whose payments exceeded the Simplified Acquisition Threshold during the audit period. Our sample was a statistically valid sample.
Questioned Costs – None noted.
Recommendation – We recommend the Organization provide periodic training to its program staff regarding procurement requirements per the Uniform Guidance and consider modifying its procurement related internal controls to ensure all staff follow the Organization’s procurement policies.
View of Responsible Officials:
We are in agreement with the finding and are in the process of updating our procedures to mitigate issues in the future. See our Corrective Action Plan for the fiscal year ended June 30, 2023 for additional detail.