CITY OF PISMO BEACH

Condition: The City did not formally document that they would continue to use the previous Uniform Guidance in their internal procurement policies during the implementation grace periods. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) direct the administration of Federal awards issued by Federal awarding agencies regulations were changed and became effective by December 26, 2014 with implementation grace periods specific to federal procurement requirements until fiscal years beginning on or after December 26, 2017. However, in order to utilize these grace periods, nonfederal agencies must document their decision in their internal procurement policies that they are choosing to use the previous procurement standards for all or part of the three fiscal year grace periods. Questioned Costs: None. Cause: The City was unaware they had to formally document in their internal procurement policies the decision to utilize the implementation grace periods. Effect: The City?s internal procurement policies are not in compliance with ?200.317 through ?200.326 of the Uniform Guidance. Perspective Information: There was only one procurement policy related to the above grant awards with the City. Recommendation: We recommend that the City update their internal procurement policies to be in compliance with the Uniform Guidance. Management?s Response: The City has updated their internal procurement policies to be in compliance with the Uniform Guidance and was approved by the City Council on September 3, 2019 in Resolution R-2019- 065.