City of Norwalk, ConnecticutLocal Government

Procurement Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Management has implemented a revised procurement policy which complies with Uniform Guidance. However, it was not in place for the entire fiscal year. Cause: The City did not have the resources necessary to implement a conforming policy until the last month of the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2023-001. Recommendation: We recommend that the City monitors the applicable federal guidance and standards for any future changes to be incorporated into the City’s procurement standards. Views of responsible officials: Management agrees with this finding.

Procurement Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 / 10.555 / 10.559 / 10.582 Federal Award Identification Number and Year: Various - 2024 Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20508 12060-SDE64370-20540 12060-SDE64370-20548 12060-SDE64370-20560 12060-SDE64370-22051 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The City failed to solicit quotations related to a contract paid under the grant. Questioned costs: $40,357 Context: The City is required by local/federal policy to solicit competitve quotations for contracts over $10,000. Cause: The City considered expenditures to this vendor as a series of micropurchases, therefore did not solicit bids. However, as the annual amount is known/estimable and work performed on a regular periodic basis, this cannot be considered as micropurchases on an as-needed basis. Effect: Immaterial noncompliance with local procurement policy and federal procurement guidelines. Repeat Finding: No Recommendation: We recommend that the City review its procurement processes to ensure they comply with local policies and federal guidance. Views of responsible officials: Management agrees with this finding.

Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A – applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the City did not have a policy in place in conformity with the federal uniform guidance criteria, the City did follow its procedures as they relate to the contracts under the procurements applicable to the City’s major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2022-001. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.

Federal Agency: All Federal Agencies Federal Program Name: All Federal Programs Assistance Listing Number: All Assistance Listing Numbers Federal Award Identification Number and Year: N/A ? applies to all Federal Programs Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: N/A Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters (Noncompliance) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None noted. Context: Although the City did not have a policy in place in conformity with the federal uniform guidance criteria, the City did follow its procedures as they relate to the contracts under the procurements applicable to the City's major program. Cause: The City did not have the resources necessary to implement a conforming policy during the fiscal year under audit. Effect: With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Yes, repeat of finding 2021-001. Recommendation: We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.

Finding No. 2021-001Procurement and Suspension and DebarmentProgramAll Federal ProgramsType of Finding:Significant Deficiency in Internal Control over ComplianceCriteriaThe City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326within Uniform Guidance.ConditionThe City?s procurement standards do not include the essential elements as outlined in 2 CFR sections200.318 through 200.326.Questioned CostsNone noted.ContextAlthough the City did not have a policy in place in conformity with the federal uniform guidance criteria,the City did follow their procedures as it relates to the contracts under the procurements applicable to theCity's major program.CauseThe City was not aware of the details surrounding the new procurement standards until FY2020 and havenot yet updated their policy to reflect the new standards.EffectWith the absence of a compliant policy, the City is at risk for noncompliance as it relates to federalprocurement.Repeat FindingYes, 2020-001RecommendationWe recommend that the City review its formal procurement policies and make necessary changes tocomply with the criteria as set out in 2 CFR sections 200.318 and 200.326.Views of Responsible OfficialsManagement agrees with this finding.

Finding No. 2021-002Period of PerformanceProgramUnited States Department of the TreasuryCoronavirus Relief FundAssistance Listing # 21.019Passed through the State Department of Education12060-SDE64370-29561Award period: 3/1/2020 through 12/30/2020Type of FindingOther MattersSignificant Deficiency in Internal Control over ComplianceCriteriaCoronavirus Relief Funds passed through and administered by the State of Connecticut Department ofEducation must have been incurred by December 30, 2020 with payments made within 120 days afterthat date. ConditionOut of forty expenditures selected for testing which were paid between 1/1/2021 and 4/30/2021, oneexpenditure in the amount of $258 was noted to pertain to January 2021, which was outside the periodof performance and thirteen expenditures totaling $119,363 were paid after 4/30/2021, more than 120days after the period of performance.Questioned Costs$119,621ContextTotal expenditures reimbursed through the State of Connecticut Department of Education for the NorwalkPublic Schools were $5,414,209. Questioned costs represent only 2% of the population.CauseTurnover and remote work of staff within the Norwalk Public Schools finance office as well as continuedvendor delays as a result of the Pandemic.EffectThe State of Connecticut could disallow these expenditures.Repeat FindingNoRecommendationWe recommend Norwalk Public Schools review its control procedures around the reporting ofexpenditures for reimbursement to ensure compliance with period of performance requirements.Views of Responsible OfficialsManagement agrees with this finding.

Finding No. 2020-001 Procurement and Suspension and Debarment Program All Federal Programs Criteria The City must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs None noted. Context Although the City did not have a policy in place in conformity with the federal uniform guidance criteria, the City did follow their procedures as it relates to the contracts under the procurements applicable to the City's major program. Effect With the absence of a compliant policy, the City is at risk for noncompliance as it relates to federal procurement. Cause The City was unaware of the details surrounding the new procurement standards. Recommendation We recommend that the City review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Actions Management agrees with this finding.