Efficiency Maine TrustLocal Government

2024-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Trust is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Trust is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Trust does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The Trust has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the Trust’s procurement policy are as follows: • Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms • Bonding requirements • Contract provisions • Subrecipient and contractor determinations • Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Trust’s procurement policy appropriately. This would include adding any missing components to the Trust’s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.

2023-001 State and Local Fiscal Recovery Funds – Compliance & Internal Control Criteria: In accordance with 2CFR 200.430(i), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Budget estimates alone to do not qualify as support for charges to Federal awards. Condition: The Trust allocates employee payroll to Federal awards using a budgeted allocation percentage that may not be reflective of the actual time worked by the employee on Federal and non-Federal activities. Budgeted estimates are not adjusted to actual time worked on Federal programs during the year. Cause: The Trust currently does not have a system to track the number of hours personnel work on various Federal or non-Federal programs. Effect: Payroll expenditures may not be reflective of actual time worked on Federal grants. Federal expenditures may be overstated or understated. Known Questioned Costs: unknown Likely Questioned Costs: unknown Recommendations: We recommend the Trust implement a time tracking system that requires employees to provide detail on the number of hours worked on Federal and non-Federal programs on their timesheets. The time tracking data should be utilized to charge payroll to Federal awards.