EIN: 356000948
UEI: JLGFNFM9ENK3
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 11, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 11, 2023 (1287 days ago).
What is a management decision? →FINDING 2021-001 Subject: COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program - Procurement Federal Agency: Department of Transportation Federal Program: COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program Assistance Listings Number: 20.509 Federal Award Number and Year (or Other Identifying Number): IN-2020-007-00 Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the City to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The City had a purchasing policy that reflected applicable state statutes; however, the policy did not cover the acquisition of property or services between $10,000 and $50,000 which fall within the small purchase procurement method for federal programs. Additionally, the policy did not address procurement requirements for micro-purchases and the need to document the rationale for the vendors utilized. For all 17 of the micro-purchase vendors selected for testing, no documentation was provided to support the rationale to limit competition or to support why the limitation was justified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) Micro-purchases - (i) Distribution. The acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (. . . ? 200.1). To the maximum extent practicable, the non-Federal entity should distribute micropurchases equitably among qualified suppliers. (ii) Micro-purchase awards. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micropurchases if procedures are documented and approved by the non-Federal entity. . . ." Cause Management had not established a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal funds to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City's management establish a system of internal control to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2021-001 Subject: COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program - Procurement Federal Agency: Department of Transportation Federal Program: COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program Assistance Listings Number: 20.509 Federal Award Number and Year (or Other Identifying Number): IN-2020-007-00 Pass-Through Entity: Indiana Department of Transportation Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the City to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The City had a purchasing policy that reflected applicable state statutes; however, the policy did not cover the acquisition of property or services between $10,000 and $50,000 which fall within the small purchase procurement method for federal programs. Additionally, the policy did not address procurement requirements for micro-purchases and the need to document the rationale for the vendors utilized. For all 17 of the micro-purchase vendors selected for testing, no documentation was provided to support the rationale to limit competition or to support why the limitation was justified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) Micro-purchases - (i) Distribution. The acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (. . . ? 200.1). To the maximum extent practicable, the non-Federal entity should distribute micropurchases equitably among qualified suppliers. (ii) Micro-purchase awards. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micropurchases if procedures are documented and approved by the non-Federal entity. . . ." Cause Management had not established a system of internal control that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal funds to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City's management establish a system of internal control to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2021-001 Contact Person Responsible for Corrective Action: Marsha Pfeiffer, Clerk- Treasurer Contact Phone Number: (812)-275-1606 Views of Responsible Official: I concur with the finding The City has a purchasing policy that covers the acquisition of property or services between $10,000 and $50,000 which falls within the procurement of small purchases and follows the requirements set forth by state statutes. As of this date we will begin working on establishing a Federal Procurement Policy that will be approved and adopted by the Mayor and Common Council as a Federal Procurement Policy Ordinance. This Ordinance will state the Federal Government requirements for the procurement of goods, materials, and services in accordance with Title 2, Part 200 of the Code of Federal Regulations. It is in the city?s best interest to establish a purchasing policy to comply with Federal regulations and to promote economic efficiency and continuity in purchasing. Anticipated Completion Date: August 15,2022 (Date of Common Council Meeting) Sincerely, Marsha Pfeiffer, Clerk-Treasurer
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