THE WOODLANDS TOWNSHIP

Finding #2021-001 ? Significant Deficiency and Other Non-Compliance Applicable federal programs: U. S. Department of Transportation: Federal Transit Formula Grants ? Federal Transit Cluster Urbanized Area Formula Program; Section 5307 09/08/17 ? 10/31/23 20.507 TX-2017-056-00 09/19/19 ? 12/31/22 20.507 TX-2019-083-00 08/21/20 ? 12/31/24 20.507 TX-2020-157-00 08/12/20 ? 07/30/25 20.507 TX-2020-155-00 Bus and Bus Facilities Formula, Competitive and Low or No Emissions Programs ? Federal Transit Cluster Bus and Bus Facilities Formula Program; Section 5339 08/28/18 ? 12/31/22 20.526 TX-2018-061-00 08/05/21 ? 08/31/23 20.526 TX-2021-062-00 Criteria: Procurement ? Uniform Guidance ?200.318 states that the Township must have and use documented procurement procedures consistent with state and local laws and regulations and the Uniform Guidance procurement standards. The Township?s procurement policy states that documentation must be maintained in the vendor file that indicates the vendor was verified not to be suspended, debarred, or otherwise excluded. Condition and context: In a sample of 5 vendors with contracts meeting the threshold for determination that the vendor was not suspended or debarred, we noted 4 of the vendor files did not contain documentation that the vendor had not been suspended, debarred, or otherwise excluded. Cause: The Township did not appropriately apply its procurement policy and maintain documentation of the verification of suspension, debarment, or exclusion status. Effect: The failure to follow the established procurement policy could result in the Township?s purchase of goods or services from a vendor that has been suspended, debarred, or otherwise excluded and, as a result, lead to costs being determined unallowable by the federal granting agency. Questioned costs: Unknown Recommendation: Re-emphasize to program personnel the need to adhere to the established procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-002 ? Significant Deficiency and Other Non-Compliance Applicable federal program: U. S. Department of Transportation: Federal Transit Formula Grants ? Federal Transit Cluster Urbanized Area Formula Program; Section 5307 08/12/20 ? 07/30/25 20.507 TX-2020-155-00 Criteria: Procurement ? Uniform Guidance ?200.320 states that the Township must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold, including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation. Condition and context: During our testing of the Section 5307 grant, we noted that the Mobile Ticketing Consulting Services contract expired within the fiscal period. The Township continued to contract with the vendor for the remainder of the fiscal year. This was done without documenting the required cost or price analysis. Cause: The Township did not appropriately apply its adopted procurement policies in the extension of services for the mobile ticketing contract. Effect: The failure to follow the established procurement policy could result in the Township?s purchase of goods or services at a cost in excess of what could have been obtained if competitive procurement policies had been utilized and lead to costs being determined unallowable by the federal granting agency. Questioned costs: Unknown Recommendation: Re-emphasize to program personnel the need to adhere to the established procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2019-001 ? Other Non-Compliance Applicable federal program: U. S. Department of Transportation: Federal Transit Formula Grants ? Federal Transit Cluster Urbanized Area Formula Program; Section 5307 09/19/19 ? 12/31/22 20.507 TX-2019-083-00 Criteria: Procurement ? Uniform Guidance ?200.323 states that the Township must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold, including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation. Condition and context: During our testing of the Section 5307 grant, we noted that the Transit Consulting Services contract had been set to expire within the fiscal period. The Township amended the contract to extend the term for an additional twelve months. This was done without documented procurement evaluation and justification of the proposed costs of the change order. Cause: The Township did not appropriately apply its adopted procurement policies in the extension of services for transit consulting. Effect: The failure to follow their procurement policy and Uniform Guidance could result in The Township?s purchase of goods or services at a cost greater than obtained if competitive procurement policies had been utilized and lead to costs being determined unallowable by the federal agency. Questioned costs: Unknown Recommendation: Re-emphasize to program personnel the need to adhere to grant program requirements regarding procurement methodologies. Views of responsible officials and planned corrective action: The Township personnel revised the Township?s FTA Procurement Guidelines to assist Township staff with change order procedures for new and/or existing procurements. The updated document details the procedures that should be followed to determine whether a cost increase or reduction is justifiable for a contract. The Township submitted the updated FTA Procurement Guidelines document to FTA?s region 6 staff for review on January 6, 2020. At this time, the Township is still awaiting feedback on the submission of the deficiencies from the 2019 Triennial Review.

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