CITY OF HURONLocal Government

Criteria: Title 2 CFR, Subpart B-General Provisions, Section 200.110(a) states that for the procurement standards in Sections 200.317 through 200.326, non-Federal entities may continue to comply with the procurement standards in previous OMB guidance (as reflected in Section 200.104) for a total of three fiscal years after the Uniform Guidance goes into effect. As such, the effective date for implementation of the procurement standards for non-Federal entities will start for fiscal years beginning on or after December 26, 2017. If a non-Federal entity chooses to use the previous procurement standards for all or part of these three fiscal years before adopting the procurement standards in this part, the non-Federal entity must document this decision in its internal procurement policies. Condition: As part of our audit testing, we examined the procurement policy of the City and compared it to the standards of procurement described in the Uniform Guidance. We noted that the City has not updated its procurement policy to comply with the Uniform Guidance standards, and that no documentation of the City?s decision to take advantage of the grace period offered by OMB for implementation in fiscal year 2017-18, was included in the City?s internal procurement policies. Questioned Cost: There were no questioned costs identified ($0). Cause: The City was not aware of the requirement to document the decision in the purchasing policy to take advantage of the grace period. Effect: The procurement policy in use by the City at June 30, 2019 does not comply with the requirements of Sections 200.317 through 200.326 of the Uniform Guidance. Context: The City has one procurement policy which covers all procurements, including those made with Federal Funds. Repeat Finding: New finding for fiscal year ended June 30, 2019.