Audit 27335

Criteria and Condition: Uniform Guidance section 200.318 states non-Federal entities must maintain records sufficient to detail the history of procurements. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Cause: We selected one vendor, out of the four which were paid an amount over CEF?s micro-purchase threshold for testing. We noted that the vendor file did not contain documentation that the vendor was not suspended or debarred, nor did it contain documentation regarding the selection process. Effect: Procuring vendors without full and open competition. Context: Vendor file selected for testing of procurement and suspension and debarment did not have proper documentation as required by the Uniform Guidance. Questioned costs: This finding did not result in any questioned costs. Recommendation: We recommend that CEF institute an internal policy that the selection process for all procurements over the organization?s micro-purchase threshold be documented and retained in a vendor file. This should also include documentation to support that a search that was performed on the SAM.gov website to verify that the vendor is not suspended or debarred. CEF should also update its procurement policies to be in compliance with the revised Uniform Guidance, which may allow for CEF to increase its micro-purchase threshold from $10,000 to $50,000 if certain criteria is met.

Criteria and Condition: Uniform Guidance section 200.318 states non-Federal entities must maintain records sufficient to detail the history of procurements. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Cause: We selected one vendor, out of the four which were paid an amount over CEF?s micro-purchase threshold for testing. We noted that the vendor file did not contain documentation that the vendor was not suspended or debarred, nor did it contain documentation regarding the selection process. Effect: Procuring vendors without full and open competition. Context: Vendor file selected for testing of procurement and suspension and debarment did not have proper documentation as required by the Uniform Guidance. Questioned costs: This finding did not result in any questioned costs. Recommendation: We recommend that CEF institute an internal policy that the selection process for all procurements over the organization?s micro-purchase threshold be documented and retained in a vendor file. This should also include documentation to support that a search that was performed on the SAM.gov website to verify that the vendor is not suspended or debarred. CEF should also update its procurement policies to be in compliance with the revised Uniform Guidance, which may allow for CEF to increase its micro-purchase threshold from $10,000 to $50,000 if certain criteria is met.