Senior Resource Development Agency Pueblo, Inc.

Procurement, Suspension, and Debarment Formula Grants for Rural Areas

Criteria: A recipient of federal awards is required to ensure that contractors are checked against the debarment list and ensure there are controls in place over procurement per 2 CFR section 180.220.

Condition and Context: The Organization did not check contractors against the debarment list. The Organization does have a formally documented process in place to ensure all procurement requirements were completed accurately and timely.

Cause: The Organization was not aware that they needed to check vendors against the debarment list.

Effect or Potential Effect: Without checking vendors against the debarment list, the Organization is unable to ensure that federal regulations were complied with.

Recommendation: We recommend the Organization update their policies and procedures manual to ensure that they test contractors to the debarment list when expenses reach federal limits and that proof of the search is retained.

Identification of Repeat Audit Finding: No

Responsible Official’s Response: Management agrees with the recommendation to establish and follow a documented internal control process over the review of procurement. Staff will work with management to ensure that contractors with expenses over federal limits will be tested against the debarment list and support such. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.

Procurement, Suspension and Debarment Formula Grants for Rural Areas

Criteria: The Organization is required to have documented procurement policies and procedures which comply with the compliance requirements: UG §200.318 general procurement standards, UG §200.319 competition, and UG §200.320 methods of procurement to be followed.

Condition and Context: The Organization has a formally documented purchasing and procurement policy. However, the Organization does not keep formal records demonstrating its adherence to the procurement policy for contractors.

Cause: The Organization was not aware that it needed to retain proof of the contractors going through the procurement process.

Effect or Potential Effect: Without sufficient documentation, the Organization may have selected a vendor outside the parameters of the procurement policy. If not documented, the Organization may not detect errors in the procurement process.

Recommendation: We recommend the Organization update their policies and procedures manual to ensure that prior to a vendor being selected, there must be a formally documented file for each vendor noting how the vendor qualifies to work for the Organization and that the policies and procedures manual was adhered to.

Identification of Repeat Audit Finding: No

Responsible Official’s Response: Management agrees with the recommendation to establish and follow a documented internal control process over the review of the procurement process. Staff will work with management to ensure that all contractors going through the bidding process will be evaluated using the policies and procedures manual. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.