Audit 294874

Condition: The Organization had covered transactions for goods and services that exceeded $25,000 during the year. Prior to entering into the covered transactions, the Organization did not verify that the service provider was not suspended, debarred, or otherwise excluded by the Federal Government. Context: The Organization made payments to four vendors for services and goods in excess of $25,000, per vendor, during the period of the audit. Per our testing, the Organization did not have documentation showing that prior to entering into transactions with the vendors the Organization verified that the vendors were not suspended or disbarred by the Federal Government. As part of our testing, we verified that all four vendors were not suspended or disbarred. Cause: The Organization does not have a process in place to identify covered transactions or verify that entities providing goods or services are not suspended or debarred. Criteria: The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Effect: The Organization entered into covered transactions without knowing if the entity was suspended or disbarred from the transaction. Recommendation: We recommend that the Organization establish a written policy that identifies when the Organization enters a covered transaction and the necessary steps to take prior to entering into a covered transaction to verify that an entity is not suspended or disbarred. Management’s Response: Management agrees.

Condition: The Organization does not have a documented procurement policy that conforms to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Context: During the year, the Organization made a purchase of property that was greater than the Simple Acquisition Threshold of $250,000. As part of the audit procedures, we requested the Organization’s documented procurement policy. The Organization did not have a documented procurement policy. Prior to making purchases in excess of the simplified acquisition threshold, the Organization performed a price analysis in a manner consistent with 2 CFR Part 200. Cause: The Organization was not aware that a documented procurement policy was required. Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effect: Without documented procurement policies, the Organization could procure assets in a manner that is not consistent with 2 CFR Part 200. Recommendation: We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318 through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and procurement requirements. Management’s Response: Management agrees.

Condition: The Organization had covered transactions for goods and services that exceeded $25,000 during the year. Prior to entering into the covered transactions, the Organization did not verify that the service provider was not suspended, debarred, or otherwise excluded by the Federal Government. Context: The Organization made payments to four vendors for services and goods in excess of $25,000, per vendor, during the period of the audit. Per our testing, the Organization did not have documentation showing that prior to entering into transactions with the vendors the Organization verified that the vendors were not suspended or disbarred by the Federal Government. As part of our testing, we verified that all four vendors were not suspended or disbarred. Cause: The Organization does not have a process in place to identify covered transactions or verify that entities providing goods or services are not suspended or debarred. Criteria: The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Effect: The Organization entered into covered transactions without knowing if the entity was suspended or disbarred from the transaction. Recommendation: We recommend that the Organization establish a written policy that identifies when the Organization enters a covered transaction and the necessary steps to take prior to entering into a covered transaction to verify that an entity is not suspended or disbarred. Management’s Response: Management agrees.

Condition: The Organization does not have a documented procurement policy that conforms to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Context: During the year, the Organization made a purchase of property that was greater than the Simple Acquisition Threshold of $250,000. As part of the audit procedures, we requested the Organization’s documented procurement policy. The Organization did not have a documented procurement policy. Prior to making purchases in excess of the simplified acquisition threshold, the Organization performed a price analysis in a manner consistent with 2 CFR Part 200. Cause: The Organization was not aware that a documented procurement policy was required. Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effect: Without documented procurement policies, the Organization could procure assets in a manner that is not consistent with 2 CFR Part 200. Recommendation: We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318 through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and procurement requirements. Management’s Response: Management agrees.