Finding Text
Federal Agency: U.S. Department of Justice
Federal Program Title: Crime Victim Assistance
Federal Assistance Listing Number: 16.575
Pass-Through Agency: Minnesota Office of Justice Programs
Pass-Through Number(s): A-CVS-2022-AMS-157
Award Period: 10/01/2021 to 09/30/2023
Type of Finding:
• Material Weakness in Internal Control over Major Federal Programs, Material Noncompliance, and Other Matters
Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: The Organization does not have a written procurement policy in accordance with Uniform Guidance. In addition, during our testing, we noted the Organization did not apply any procurement procedures for three small purchases as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance.
Questioned Costs: $46,557
Context: The Organization should develop a procurement policy that conforms with Uniform Guidance. Three out of the three procurement selections did not have procurement procedures followed.
Cause: The Organization was unaware its policy was not in accordance with Uniform Guidance; thus, leading to the lack of procedures performed and documentation retained.
Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements.
Views of Responsible Officials and Planned Corrective Actions: The Organization will review the procurement standards as well as provide the necessary training to understand applicable procurement requirements.