Finding Text
Finding No. 2022-003 – Procurement and Suspension and Debarment
Federal Agency: U.S. Department of Treasury
Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number: N/A
Award Period: March 2021 through December 2026
Type of finding:
Significant Deficiency in Internal Control over Compliance and Other Matters
Condition:
During our testing, we noted the County did not have internal controls designed to ensure compliance with federal procurement and suspension and debarment requirements.
Criteria or specific requirement:
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The County should have internal controls designed to ensure compliance with those provisions.
Questioned costs:
None
Context:
During our testing, it was noted that none of the six transactions tested had proper documentation to verify federal grant procurement requirements were complied with. Additionally, it was noted the County did not have an internal control to properly ensure the one contractor utilized was not suspended or debarred.
Cause:
The County does not have a written procurement policy in place that clearly addresses compliance with federal grant requirements per the Uniform Guidance.
Effect:
The County’s noncompliance with procurement and suspension and debarment requirements could lead to a negative impact on future funding for the County.
Repeat finding: No
Recommendation:
We recommend the County review the federal procurement requirements outlined in the federal Uniform Guidance and create a written policy to address federal compliance requirements. Additionally, we recommend a designated individual at the County ensures purchases made with federal grant funding comply with federal procurement requirements by type of procurement (micropurchase, small purchase, sole-source, etc) and also suspension and debarment requirements.