Finding Text
Information on the Federal Program: Assistance Listing Number 21.027-Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of the Treasury. Compliance Requirements: Procurement. Type of Finding: Material Weakness in Internal Control Over Compliance.
Criteria: Internal controls should be in place to provide reasonable assurance that procurement of goods and services are made in compliance with federal regulations and other procurement requirements, as applicable.
Condition: The County lacks sufficient controls over procurement to ensure compliance with federal regulations and other procurement requirements, as applicable.
Cause: The County did not design and implement controls over compliance with procurement.
Effect or Potential Effect: Failure to have adequate internal controls over compliance with procurement could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, and other procurement requirements.
Questioned Costs: There are no questioned costs.
Recommendation: We recommend that the County create and adopt an official written policy for procurement and contracts establishing contract files that document significant procurement history; methods of procurement authorized including selection of contract type, contractor selection or rejection, and the basis of contract price; verification that procurements provide full and open competition; requirements for cost or price analysis, including for contract modifications; obtaining and reacting to suspension and debarment certifications; and other applicable requirements for procurements under federal awards are followed. We also recommend that personnel with adequate knowledge and experience of responsibilities for procurements for federal awards review procurement and contracting decisions for compliance with federal procurement policies.
Views of Responsible Officials and Planned Corrective Action: Management concurs with the audit finding. The County will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where County personnel are not available or qualified to perform.