oversight

The City of Minot, ND, Did Not Fully Comply With Federal and Local Procurement Requirements

Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-03-13.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  The City of Minot, ND
              Community Development Block Grant
                 Disaster Recovery Program




Office of Audit, Region 7       Audit Report Number: 2015-KC-1002
Kansas City, KS                                     March 13, 2015
To:            Edward Atecnio, Acting Director, Denver Office of Community Planning and
               Development, 8AD
               //signed//
From:          Ronald J. Hosking, Regional Inspector General for Audit, 7AGA
Subject:       The City of Minot, ND, Did Not Fully Comply With Federal and Local
               Procurement Requirements


Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of the City of Minot, ND’s Community Development
Block Grant Disaster Recovery program.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
913-551-5870.
                    Audit Report Number: 2015-KC-1002
                    Date: March 13, 2015

                    The City of Minot, ND, Did Not Fully Comply With Federal and Local
                    Procurement Requirements




Highlights

What We Audited and Why
We audited the City of Minot, ND’s Community Development Block Grant (CDBG) Disaster
Recovery program because the City was awarded more than $67 million in CDBG Disaster
Recovery funds in April 2012 and an additional $35 million in May 2013. Before our audit, the
City had spent more than $26 million and $1.3 million, respectively. In addition, we had not
audited the City’s activities in more than 10 years. Our audit objective was to determine whether
the City complied with Federal and local procurement requirements.

What We Found
The City did not fully comply with Federal and local procurement requirements. It did not
prepare independent cost estimates before receiving bids or proposals for two grant
administration and project delivery services contracts and the five amendments to those contracts
or for the change orders for four construction projects. In addition, the City did not perform
debarment checks before awarding three contracts. The City’s mayor signed two amendments
for the 2012 grant administration and project delivery contract before the city council authorized
the mayor to sign the documents on the City’s behalf. Finally, one construction contract was not
dated and did not have an effective date of services.

What We Recommend
We recommend that HUD (1) require the City to provide documentation demonstrating that the
overall contract price for the two grant administration and project delivery services and the five
amendments to those contracts totaling more than $11.5 million was fair and reasonable and if
not, require the City to repay HUD from non-Federal funds any amount that it cannot support;
(2) require the City to provide documentation demonstrating that the overall price for the change
orders for the four construction projects totaling $121,771 was fair and reasonable and if not,
require the City to repay HUD from non-Federal funds any amount that it cannot support; and (3)
monitor the City to ensure that it follows its revised Federal grant procurement policy and newly
adopted procurement checklist.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: The City Did Not Fully Comply With Federal and Local Procurement
         Requirements..................................................................................................................... 4

Scope and Methodology ...........................................................................................8

Internal Controls ....................................................................................................10

Appendixes ..............................................................................................................11
         A. Schedule of Questioned Costs .................................................................................. 11

         B. Auditee Comments and OIG’s Evaluation ............................................................. 16

         C. Criteria ...................................................................................................................... 20




                                                                     2
Background and Objective
Minot, ND, is located in north central North Dakota and is the fourth largest city in the State. It is
the county seat of Ward County and a trading center for a large portion of northern North Dakota,
southwestern Manitoba, and southeastern Saskatchewan. The Souris River divides Minot
approximately in half, north and south. In 2010, Minot had a population of 40,888, and Ward
County had a population of 61,675.
According to the United States Army Corps of Engineers, in 2011, high soil content, above-average
snow pack, persistent moderate spring rainfall, and moderate to large summer rainfall combined
to produce multiple flood peaks and record flooding throughout the Souris River Basin. Flood
waters inundated Minot on June 20, 2011. The damage included 4,100 homes flooded, with
3,100 lost or extensively damaged. There were 11,000 individuals displaced. The water
severely damaged six of Minot’s public schools and destroyed two schools. Water inundated 12
of the 27 sanitary lift stations and all of the City’s water wells, damaging 8 river storm pump
stations, 277 street lights, and many other vital components of Minot’s infrastructure. According
to the Corps’s assessment, the flood resulted in an estimated $600 million in property and
infrastructure damage.
The U.S. Department of Housing and Urban Development (HUD) initially awarded the City of
Minot more than $67.5 million for its jurisdiction through Section 239 of the Department of
Housing and Urban Development Appropriations Act, 2012 (Public Law 112-55). Nationwide,
the Act made up to $400 million in Community Development Block Grant (CDBG) funds
available until spent for necessary expenses related to disaster relief, long-term recovery,
restoration of infrastructure and housing, and economic revitalization in the most impacted and
distressed areas resulting from a major disaster.
HUD awarded the City an additional $35 million for its jurisdiction through the Disaster Relief
Appropriations Act of 2013 (Public Law 113-2), which provided $16 billion nationwide in
CDBG funds for necessary expenses related to disaster relief, long-term recovery, restoration of
infrastructure and housing, and economic revitalization in the most impacted and distressed areas
resulting from Hurricane Sandy and other eligible events in calendar years 2011, 2012, and 2013.
HUD signed the $67.5 million funding approval (form HUD-7082) for the City on August 8, 2012,
and the City signed it on October 24, 2012. For the $35 million CDBG Disaster Recovery grant, at
the time of our audit, HUD and the City had signed two separate partial grant agreements totaling
$29.2 million. HUD signed the funding approvals on January 6, 2014, for $20.4 million and
September 14, 2014, for $8.8 million. The City signed the agreements on January 13, 2014, and
September 15, 2014, respectively. The City anticipated executing the grant agreement for the
remainder of the funds in 2015. It did not sign an agreement for the full grant amount initially due
to concerns about the requirement to spend the funds within 2 years of HUD’s grant agreement date.
Our audit objective was to determine whether the City complied with Federal and local
procurement requirements.



                                                    3
Results of Audit

Finding: The City Did Not Fully Comply With Federal and Local
Procurement Requirements
The City did not fully comply with Federal and local procurement requirements. This deficiency
occurred because the City lacked detailed operational procedures and checklists for
implementing applicable procurement regulations. As a result, HUD was not assured that the
City received the best value and greatest overall benefit from more than $11.6 million in various
CDBG Disaster Recovery procurement contracts, amendments, and change orders.
City Did Not Fully Comply With Federal and Local Procurement Requirements
It did not always prepare independent cost estimates, did not perform debarment checks before
awarding three contracts, and signed two contract amendments before the city council approved
them.

       The City Did Not Always Prepare Independent Cost Estimates
       The City did not prepare independent cost estimates before receiving bids or proposals
       for two grant administration and project delivery services contracts and the five
       amendments to those contracts or for the change orders for four construction projects.
       Regulations at 77 CFR (Code of Federal Regulations) 22595 (April 16, 2012) states local
       governments are subject to 24 CFR 85.36(b) through (i), and the City certified that it
       adopted the specific procurement standards identified in 24 CFR 85.36. Regulations at
       24 CFR 85.36(f) and the City’s Federal grant program procurement policy required a cost
       or price analysis in connection with every procurement action including contract
       modifications.

       For the 2012 CDBG grant administration and project delivery services contract, the City
       did not prepare an independent cost estimate for the initial contract totaling more than
       $5.1 million and the four amendments, which totaled more than $1.9 million. The City
       also did not prepare an independent cost estimate for the 2013 CDBG grant
       administration and project delivery services contract and its one amendment. This
       contract totaled more than $3.6 million, and the amendment totaled more than $847,000.

       On November 10, 2014, the City provided us with a cost reasonableness analysis of the
       four amendments for the 2012 CDBG grant administration and project delivery services
       contract. In its analysis, the City determined that each amendment’s cost was reasonable.
       We reviewed the cost reasonableness for the four amendments to help determine the
       unsupported costs. Overall, we could not determine the cost reasonableness for
       amendments 1, 2, and 3, based on the documentation that the City provided. However,
       the documentation for amendment 4 showed that the costs were reasonable. See the table
       below.



                                                4
                                                              Contract and
2012 CDBG grant administration           Contract and
                                                           amendment amounts
  and project delivery services          amendment
                                                              determined as
   contract and amendments                 amounts
                                                            unsupported costs
          Original contract                  $5,124,416             $5,124,416
           Amendment 1                          610,000                   610,000
           Amendment 2                          487,620                   487,620
           Amendment 3                          823,025                   823,025
           Amendment 4                            24,000                         0

               Totals                        $7,069,061                $7,045,061


In addition, the City provided us with cost reasonableness data for the 2013 grant
administration and project delivery services contract. However, we could not determine,
with the documentation provided, whether this grant administration and project services
delivery contract cost was fair and reasonable. See the table below.

                                                              Contract and
2013 CDBG grant administration          Contract and
                                                           amendment amounts
  and project delivery services         amendment
                                                              determined as
    contract and amendment                amounts
                                                            unsupported costs
         Original contract                   $3,656,825             $3,656,825
           Amendment 1                          847,380                   847,380

              Totals                         $4,504,205                $4,504,205


The City also did not prepare independent cost estimates for change orders for the Central
parking structure, Master lift station, landfill expansion, and Roosevelt lift station
projects. See the table below.




                                         5
                                Project                Change order amount

                       Central parking structure                     $50,912
                           Master lift station                        56,524
                          Landfill expansion                             390
                         Roosevelt lift station                       13,945

                                Totals                              $121,771


       The City Did Not Perform Debarment Checks Before Awarding Three Contracts
       The City did not perform debarment checks before awarding three contracts. The City
       performed system for award management checks on these three contracts; however, they
       were performed after the contracts between the City and the contractor were signed. The
       system for award management replaced the excluded parties list system which identified
       parties excluded from receiving Federal contracts. Regulations at 24 CFR 85.35 prohibit
       grantees and subgrantees from awarding any contract to any party who is debarred or
       suspended. Both 2 CFR 180.300 and 2 CFR 2424.300 require some type of debarment
       check, certification, or a contractual clause or condition to help determine whether the
       person one intends to do business with is an excluded or suspended party.

       The City Signed Two Contract Amendments Before City Council Approval
       The City’s mayor signed two amendments for the 2012 grant administration and project
       delivery contract before the city council authorized the mayor to sign the documents on
       the City’s behalf. The two amendments had a date listed in the amendment language and
       below the mayor’s signature block, and the dates listed occurred before the city council
       officially approved the amendment. These actions could have caused the City liability
       issues. Also, one construction contract was not dated and did not have an effective date
       of services.
The City Lacked Detailed Operational Procedures and Checklists
The City lacked detailed operational procedures and checklists for implementing applicable
procurement regulations. The City’s procedures did not ensure that the City (1) performed a cost
or price analysis for every contract, including amendments or change orders; (2) performed
debarment checks before a contract was signed; and (3) received approval from the city council
before executing contracts. In addition, the City did not have a formal change order policy.
For the parking structure change order, the City stated that it did not see a need to complete its
own independent cost estimate before receiving bids because it was going to cap the amount of
CDBG funds contributed to the project.
As a result of our review, the City revised its Federal grant program procurement policy and
created a procurement checklist to strengthen its controls in complying with Federal and local
procurement requirements. We provided recommendations for the City to incorporate into its


                                                   6
local procurement requirements, and the City added the recommendations to its Federal grant
procurement policy and procurement checklist. On January 12, 2015, the city council approved
the City’s revised Federal grant program procurement policy and procurement checklist.
The City Did Not Ensure the Best Value for Procurement Activities
HUD was not assured that the City received the best value and greatest overall benefit from more
than $11.6 million in various CDBG Disaster Recovery procurement contracts, amendments, and
change orders. Further, the City put its Disaster Recovery funds at risk by signing the two
contract amendments before obtaining city council approval.
Conclusion
The deficiencies discussed above occurred because the City lacked detailed operational
procedures and checklists for implementing applicable procurement regulations. As a result,
HUD was not assured that the City received the best value and greatest overall benefit from more
than $11.6 million in various CDBG Disaster Recovery procurement contracts, amendments, and
change orders. Although the City had revised its Federal grant program procurement policy and
created a procurement checklist to strengthen its controls, HUD requires assurance that the City
has implemented these new procurement policies. If these policies are not implemented, HUD
cannot be assured that the City will receive the best value in its future Disaster Recovery
procurement transactions.
Recommendations
We recommend that the Director of the HUD Denver Office of Community Planning and
Development
       1A.    Require the City to provide documentation demonstrating that the overall contract
              price for the two grant administration and project delivery services contracts and
              the five amendments to those contracts totaling $11,549,266 was fair and
              reasonable and if not, require the City to repay HUD from non-Federal funds any
              amount that it cannot support.
       1B.    Require the City to provide documentation demonstrating that the overall price
              for the change orders for the four construction projects totaling $121,771 was fair
              and reasonable and if not, require the City to repay HUD from non-Federal funds
              any amount that it cannot support.
       1C.    Monitor the City to ensure that it follows its revised Federal grant procurement
              policy and newly adopted procurement checklist.




                                                7
Scope and Methodology
Our audit objective was to determine whether the City complied with Federal and local
procurement requirements.

To accomplish our objective, we

      Interviewed pertinent HUD Disaster Recovery and Special Grants Division, Denver
       Office of Community Planning and Development, and City staff;
      Reviewed Public Laws 112-55 and 113-2, the Stafford Act, applicable portions of the
       Code of Federal Regulations, Federal Register notices, and waiver requests;
      Reviewed the applicable HUD guidebook and Community Planning and Development
       notices, the City’s action plans and CDBG Disaster Recovery policies, and the City’s
       procurement policies and procedures;
      Reviewed the grant agreements between HUD and the City;
      Analyzed and reviewed contracts executed between the City and contractors;
      Obtained HUD’s monitoring review and technical assistance visit report on the City’s
       CDBG Disaster Recovery program;
      Reviewed the City’s audited financial statements and applicable internal audit reports;
      Reviewed Minot City Council meeting minutes; and
      Analyzed the City’s procurement checklist and various CDBG Disaster Recovery bid
       proposals.

We reviewed the procurement process for the grant administrator and delivery services contracts
and amendments for the 2012 and 2013 CDBG Disaster Recovery grants. Also, we
nonstatistically selected five projects from the City’s project listing to review. From the 2012
CDBG Disaster Recovery grant, we reviewed 4 of the 21 projects. The Federal dollars for these
four projects totaled more than $14.4 million, or 42.15 percent of the total Federal dollars
budgeted for the 21 projects. From the 2013 CDBG Disaster Recovery grant, we selected one of
the six projects, totaling $9.1 million, or 28.86 percent of the total Federal dollars budged for the
six projects. Later, we reviewed two additional 2012 CDBG Disaster Recovery grant projects.
The total Federal dollars for these 2 projects totaled more than $4 million, or 11.82 percent of the
total Federal dollars budgeted for the 21 projects previously mentioned. We selected these
projects because they were the projects with the highest Federal dollar amounts. We cannot
project the results of our sample testing to the entire project population.

We primarily used data from the City’s files to meet our audit objective. In addition, we used
HUD’s Disaster Recovery Grant Reporting (DRGR) system data and the City’s accounting
records as support, which we confirmed with other evidence. We determined that the DRGR
data and the City’s accounting records were sufficiently reliable to meet our objective. Also, we
found that the City had a series of controls in place to verify the accuracy of the data it recorded.    



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We performed onsite work between September and November 2014 at City Hall located at 515
2nd Avenue, SW, Minot, ND, and the Minot Municipal Auditorium located at 420 3rd Avenue,
SW, Minot, ND. Our audit period generally covered April 1, 2012, through September 15, 2014;
however, we expanded the scope as necessary because various documents relevant to the City’s
CDBG Disaster Recovery program were not finalized until November 2014. This is the first in a
series of audits that we plan to conduct on the City’s CDBG Disaster Recovery program.

We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                9
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to

   Effectiveness and efficiency of operations,
   Reliability of financial reporting, and
   Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined that the following internal controls were relevant to our audit objective:

   Controls over the City’s CDBG Disaster Recovery program procurement process.

We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:
   The City lacked detailed operational procedures and checklists for implementing applicable
    procurement regulations.
.




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Appendixes

Appendix A


                             Schedule of Questioned Costs
                           Recommendation
                                             Unsupported 1/
                               number
                                   1A                $11,549,266
                                   1B                    121,771

                                 Totals              $11,671,037



1/   Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
     or activity when we cannot determine eligibility at the time of the audit. Unsupported
     costs require a decision by HUD program officials. This decision, in addition to
     obtaining supporting documentation, might involve a legal interpretation or clarification
     of departmental policies and procedures.


.




                                              11
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




                               12
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 2




                               13
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 3


Comment 4


Comment 1




                               14
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




                               15
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 5




Comment 6




Comment 7




Comment 8




Comment 9




                               16
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation


Comment 7




Comment 10




Comment 11




                               17
                         OIG Evaluation of Auditee Comments


Comment 1   The City referenced a HUD website entitled Quick Guide to Cost and Price
            Analysis for HUD Grantees and Funding Recipients; however, this is not the
            regulatory guidance that the City is required to follow. According to 77 CFR
            22595 (April 16, 2012), any unit of local government receiving a direct
            appropriation under the notice is subject to 24 CFR 85.36(b) through (i). The City
            also certified that it adopted the specific procurement standards identified in 24
            CFR 85.36. Regulations at 24 CFR 85.36(f) require grantees and subgrantees to
            perform a cost or price analysis in connection with every procurement action,
            including contract modifications. It further states the method and degree of
            analysis is dependent on the facts surrounding the particular situation, but as a
            starting point, grantees must make independent estimates before receiving bids or
            proposals. In the Quick Guide to Cost and Price Analysis for HUD Grantees and
            Funding Recipients, it also states that a cost or price analysis is required. It
            further states that 24 CFR 85 requires grantees to perform a cost or price analysis
            for every procurement action including contract modifications (e.g., change
            orders), using HUD grant funds.
Comment 2   During the audit, we asked the City if they performed any independent estimates
            before receiving bids for the two grant administration and project delivery
            services contracts. The City replied that they did not perform an independent
            analysis prior to issuing the request for proposals.

Comment 3   The City acquired their contractor services for $135 per hour. However, the City
            did not perform an estimate on the amount of labor hours required for each
            amendment and their specific tasks.

Comment 4   We could not determine if the costs were reasonable for Amendments #1, #2, and
            #3. For Amendment #1, the City did not provide documentation that they
            attempted to contact any other legal firms to see if a cheaper cost was available.
            For Amendment #2, the City stated they only talked with local housing officials
            on estimated costs but they did not contact other entities to obtain cost estimates
            for this housing study. On Amendment #3, we could not verify the City’s cost
            estimates with the provided documentation that stated the costs appeared
            reasonable for an amendment amount that was different than the actual
            amendment total.

Comment 5   We reviewed the City’s preliminary engineering report completed on August 17,
            2012 for the downtown parking structures. We agree this cost estimate was
            completed before the two contracts for the parking structures were executed and
            the analysis was thorough. As a result, we removed the portion of the finding
            regarding the City not preparing cost estimates for the procurement of two



                                              18
              parking structure projects. However, the City did not provide a cost analysis for
              the Central parking structure’s change order so this remained in the audit report.

Comment 6     We disagree that the project change orders met HUD requirements. Regulations
              at 24 CFR 85.36(f) require grantees and subgrantees to perform a cost or price
              analysis in connection with every procurement action, including contract
              modifications.

Comment 7     The debarment checks were not completed before the contracts were awarded as
              required by 2 CFR 180.300 and 2 CFR 2424.300.

Comment 8     We agree the two amendments were ultimately approved by the city council;
              however, the City’s mayor signed the two amendments for the 2012 grant
              administration and project delivery contract before the city council authorized the
              mayor to sign the documents on the City’s behalf. The two amendments had a
              date listed in the amendment language and below the mayor’s signature block
              which occurred before city council approval.

Comment 9     We disagree with the City’s assertion that the City performed a cost or price
              analysis that met HUD’s requirements. As a result of our review, the City revised
              its Federal grant program procurement policy and created a procurement
              checklist. HUD needs to monitor the City to ensure that it follows its revised
              Federal grant procurement policy and newly adopted procurement checklist.

Comment 10 We disagree with the City’s assertion that they received approval prior to signing
           all contract amendments that modified the contract price. The only dates on the
           amendments, including the date below the mayor’s signature block, occurred
           before city council approval; therefore, we found the mayor signed amendments
           #1 and #3 for the 2012 grant administration and project delivery services contract
           before the city council authorized the mayor to do so. The audit team did not
           review amendment #5.

Comment 11 We disagree that the City received the best value and greatest overall benefit for
           its CDBG disaster recovery procurements, amendments, and change orders.
           Although the City believed it followed HUD’s Guidelines for Cost and Price
           Analysis for HUD Grantees and Funding Recipients, it did not properly follow the
           appropriate regulatory guidance found in 24 CFR 85.36(f). Although the City
           rejected the notion that it lacked detailed operational procedures and checklists,
           they still revised their Federal grant program procurement policy and developed a
           procurement checklist as a result of our review. HUD needs to monitor the City
           to ensure that it follows its revised Federal grant procurement policy and newly
           adopted procurement checklist.


                                                19
Appendix C
                                           Criteria


77 CFR 22595 (April 16, 2012)
      Any unit of local government receiving a direct appropriation under today’s notice is
      subject to 24 CFR 85.36(b) through (i).
24 CFR 85.36(f)
      Grantees and subgrantees must perform a cost or price analysis in connection with every
      procurement action, including contract modifications. The method and degree of analysis
      is dependent on the facts surrounding the particular situation, but as a starting point,
      grantees must make independent estimates before receiving bids or proposals.
24 CFR 85.35
      Grantees and subgrantees must not make any award or permit any award (subgrant or
      contract) at any tier to any party that is debarred or suspended or is otherwise excluded
      from or ineligible for participation in Federal assistance programs subject to 2 CFR Part
      2424.
2 CFR 180.300
      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 may do so by checking the Excluded Parties List System (the System
      for Award Management replaced this database), collecting a certification from that
      person, or adding a clause or condition to the covered transaction with that person.
2 CFR 2424.300
      As a participant, you are responsible for determining whether you are entering into a
      covered transaction with an excluded or disqualified person. You may decide the method
      by which you do so. You may but are not required to check the Excluded Parties List
      System or collect a certification from that person.
City of Minot, ND, Federal Grant Program Procurement Policy
(June 2012 and June 2013 editions)
      The City shall perform cost or pricing analysis in connection with every procurement
      action, including contract modifications, in accordance with the requirements of “Cost
      and Price Analysis for HUD Grantees and Funding Recipients.”




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