Finding Text
Assistance Listing Number(s): 21.027
Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Name of Federal Agency: Department of the Treasury
Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce
Development
Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31,
2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a nonfederal
entity to maintain written standards of conduct covering conflicts of interest and governing the
actions of its employees engaged in the selection, award and administration of contracts. 2 CFR section
200.318(i) requires a non-federal entity to maintain records sufficient to detail the history of procurement
including, but not limited to, the: rationale for the method of procurement, selection of contract type,
contractor selection or rejection, and the basis for the contract price.
Condition and Context: There are no documented procurement procedures that meet the requirements of
2 CFR sections 200.317 through 200.327. While there is a conflict-of-interest policy, it does not
specifically include standards of conduct covering conflicts of interest for procurement. There are no
designed and implemented internal controls documented to ensure compliance with 2 CFR sections
200.317 through 200.327. For three significant transactions tested there were no documentation of the
rationale for the method, documentation to support a required procurement method used, contractor
selections or rejections, suspension and debarment, and bases for contract prices. The only support
documented are the invoices. Total procurements were $482,904.
Cause: The organization began charging procurement transactions in the current year to federal awards.
The organization’s staff did not understand how to document the procurement history.
Effect or Potential Effect: Questioned costs may be disallowed and required to be repaid.
Questioned Costs: $365,501; total of the three significant transactions tested.
Repeat Finding: No.
Recommendation: The organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. The conflict-of-interest policy should be updated to
include standards of conduct for those involved in procuring and to include organizational conflicts of
interest. Internal controls should be designed, implemented, and documented within the procurement
procedures to ensure compliance with 2 CFR sections 200.317 through 200.327. At a minimum, the
procurement history including rationale for the method, procurement method support, contract selections
and rejections, suspension and debarment, and bases for contract prices should be documented.
Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is
implementing procurement and conflict-of-interest policies.