EIN: 356001067
UEI: K72JTT5JDYE1
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 18, 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 18, 2023 (1284 days ago).
What is a management decision? →Finding 2021-001 Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of Treasury Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2021 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: Federal regulations 2 CFR section 200.318 through 200.327 and 2 CFR 180.300 require the City to: 200 CFR.318 (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. 200 CFR.320 (b-c) states in part: Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require the following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (3) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (4) After solicitation of a number of sources, competition is determined inadequate 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition and Context: An effective system of internal controls was not in place at the City to ensure compliance with requirements related to the Procurement and Suspension and Debarment compliance requirement. Procurement ? Policy: The City policies had not been updated to comply with the procurement standards outlined in 2 CFR 200.318 through 2 CFR 200.327. The City had a purchasing policy but did not tailor the policy to meet federal requirements. Procurement ? There were three procurements, representing the entire 2021 procurement population, selected for testing. For one selection, the City did not follow federal procurement requirements for a purchase which exceeded the simplified acquisition threshold of $250,000. The selection was a professional services contract for approximately $2,948,000. The City contracted with an engineering firm for the design of an expansion of a wastewater treatment plant and followed Indiana Code 5-16-11.1. However, a formal procurement method was not used for the purchase as required by federal procurement requirement as outlined in 2 CFR 200.320. The other two procurements, both simplified acquisitions, selected were supported by procurement records. Suspension and Debarment - The City did not verify that vendors with contracts over $25,000 were not excluded or disqualified from participation in federal award programs. All three selections, representing the entire population of procurements in 2021, were not verified to ensure the vendor was not excluded or disqualified from participation in federal award programs. Questioned Costs: There were no questioned costs identified. Effect: The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal funds to the City. Cause: Management had not established a federal procurement policy and system of internal controls to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Recommendation: We recommend that the City?s management establish a written federal procurement policy to supplement their organizational policies and develop a system of internal controls and written procedures to ensure compliance and comply with the grant agreement requirements and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials: Management concurs with this finding
Show full finding ▾Hide full finding ▴Finding 2021-001 Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of Treasury Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2021 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: Federal regulations 2 CFR section 200.318 through 200.327 and 2 CFR 180.300 require the City to: 200 CFR.318 (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. 200 CFR.320 (b-c) states in part: Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require the following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (3) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (4) After solicitation of a number of sources, competition is determined inadequate 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition and Context: An effective system of internal controls was not in place at the City to ensure compliance with requirements related to the Procurement and Suspension and Debarment compliance requirement. Procurement ? Policy: The City policies had not been updated to comply with the procurement standards outlined in 2 CFR 200.318 through 2 CFR 200.327. The City had a purchasing policy but did not tailor the policy to meet federal requirements. Procurement ? There were three procurements, representing the entire 2021 procurement population, selected for testing. For one selection, the City did not follow federal procurement requirements for a purchase which exceeded the simplified acquisition threshold of $250,000. The selection was a professional services contract for approximately $2,948,000. The City contracted with an engineering firm for the design of an expansion of a wastewater treatment plant and followed Indiana Code 5-16-11.1. However, a formal procurement method was not used for the purchase as required by federal procurement requirement as outlined in 2 CFR 200.320. The other two procurements, both simplified acquisitions, selected were supported by procurement records. Suspension and Debarment - The City did not verify that vendors with contracts over $25,000 were not excluded or disqualified from participation in federal award programs. All three selections, representing the entire population of procurements in 2021, were not verified to ensure the vendor was not excluded or disqualified from participation in federal award programs. Questioned Costs: There were no questioned costs identified. Effect: The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal funds to the City. Cause: Management had not established a federal procurement policy and system of internal controls to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Recommendation: We recommend that the City?s management establish a written federal procurement policy to supplement their organizational policies and develop a system of internal controls and written procedures to ensure compliance and comply with the grant agreement requirements and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials: Management concurs with this finding
Contact Person Responsible for Corrective Action: Heather Metcalf Contact Phone Number: 812-285-6492 Views of Responsible Official: We concur with the finding. The City of Jeffersonville will elect to use the standard allowance for revenue replacement of $10 million. As stated in the Final Rule enacted by U.S. Treasury effective 4/1/2022: "Recipients that select the standard allowance may use that amount for government services." Treasury's Coronavirus State and Local Fiscal Recover Funds, as of July 27, 2022, FAQ 3.3 states "Recipients may also use revenue loss funds to carry out investments that would be eligible under other eligible use categories, because those eligible uses are also services provided by recipient governments." Additionally, FAQ 13.15 clarifies which regulations in Uniform Guidance apply to funds expended under Expenditure Category Group 6 "Revenue Replacement." Uniform Guidance regulations 2 CFR 200.318 through 200.321, cited as the criteria of the finding referenced above, are not included in the list of applicable regulations from subpart D of the Uniform Guidance to Expenditure Category 6 "Revenue Replacement." Further, FAQ 13.15 states, "In general, these requirements provide that recipients should not deviate from their established practices and policies regarding the incurrence of costs, and that they should expend and account for the funds in accordance with laws and procedures for expending and accounting for the recipient's own funds." We maintain that the expenditures noted in the finding were expended and accounted for in accordance with the laws and procedures for expending City funds. Regarding Suspension and Debarment, FAQ 13.14 states "Recipients' use of revenue loss funds does not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award." The definition of Contract in Uniform Guidance 2 CFR 200.1 states "Contract means, for the purpose of Federal financial assistance, a legal instrument by which a recipient or subrecipient purchases property or services needed to carry out the project or program under a Federal award," Given the interpretation in FAQ 13.14, FAQ 13.15, and the Uniform Guidance Definition of "Contract" it is our position that Suspension and Debarment requirements found in 2 CFR 180.300, cited in the finding referenced above, are also not applicable to contracts and sub awards expended from Category 6 Revenue loss. Description of Corrective Action Plan: The City will classify the expenditures into Category Group 6, "Revenue Replacement" as allowed by the Final Rule on the next SLFRF quarterly compliance reporting to the US Treasury. Anticipated Completion Date: 12/31/2022
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