MIDLOTHIAN VILLAGE OF

2025-008: Procurement Policy Information on the federal program: 66.468 – Capitalization Grants for Drinking Water State Revolving Fund Environmental Protection Agency (EPA) Passed through Illinois EPA L174235 and C176673 Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.318 requires that recipients of Federal awards maintain and use documented procedures for procurement transactions. Condition: We noted that the Village does not have a documented procurement policy in place as required by 2 CFR 200.318. No instances of noncompliance were identified in the procurement transactions tested. Cause: Management has not yet developed or formally adopted procurement policies and procedures consistent with the Uniform Guidance requirements. Effect or potential effect: The lack of a documented procurement policy may result in procurement activities that are not compliant with federal requirements. Questioned costs: None Context: We reviewed procurement practices related to purchases made under federal programs during the audit period. Procurement transactions selected for testing complied with applicable federal requirements. Identification as a repeat finding, if applicable: Not applicable Recommendation: We recommend that the Village develop and adopt a written procurement policy that aligns with the requirements of 2 CFR 200.318–.326 to strengthen internal control over procurement activities. Views of responsible officials and planned corrective actions: A purchasing and procurement policy was created and discussed at the May 2026 finance committee meeting and approved by the board in May 2026.