Audit 301149

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. The Center has adopted a procurement policy that complies with the applicable procurement requirements. For purchases or contracts that have a value in excess of $10,000, three written proposals must be submitted to the Board of Directors. Condition: Procurement documentation for two vendors was not prepared. Context: We selected two contracts whose expenditures exceeded $10,000 noting that for these selections, the Center’s documentation supporting the procurement process was not prepared. Cause: Although the Center has established procurement policies and procedures, in one instance, there was a misunderstanding regarding the application of the procurement policy. Management believed that having the vendor explicitly specified in the approved grant application exempted the Center from following its procurement policy. In the second instance, management contracted with the service provider as an emergency procurement during the pandemic and did not revisit the procurement of this vendor. Effect: Failure to properly perform the procedures required under the procurement process could result in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the Center follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Management Response: To ensure future compliance with procurement policy the following action has/will be taken: 1. Management has developed a Service & Contract Procurement form that will be attached to purchase agreements/contracts for services that is or has the reasonable potential to meet or exceed $10,000 over the contract period. Service & Contract Procurement form contains the following information: a. Description of solicited services; b. Summary of written proposals; c. Basis for the selection of the vendor; d. If an emergency procurement for ongoing services, timeline for complete formal procurement process; and e. Date on which Board of Directors approved the service contract. 2. The entire management team received refresher training on the agency’s procurement policy on March 21, 2024; and 3. Management will solicit formal written proposals for professional accounting services by June 30, 2024.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. The Center has adopted a procurement policy that complies with the applicable procurement requirements. For purchases or contracts that have a value in excess of $10,000, three written proposals must be submitted to the Board of Directors. Condition: Procurement documentation for two vendors was not prepared. Context: We selected two contracts whose expenditures exceeded $10,000 noting that for these selections, the Center’s documentation supporting the procurement process was not prepared. Cause: Although the Center has established procurement policies and procedures, in one instance, there was a misunderstanding regarding the application of the procurement policy. Management believed that having the vendor explicitly specified in the approved grant application exempted the Center from following its procurement policy. In the second instance, management contracted with the service provider as an emergency procurement during the pandemic and did not revisit the procurement of this vendor. Effect: Failure to properly perform the procedures required under the procurement process could result in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the Center follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Management Response: To ensure future compliance with procurement policy the following action has/will be taken: 1. Management has developed a Service & Contract Procurement form that will be attached to purchase agreements/contracts for services that is or has the reasonable potential to meet or exceed $10,000 over the contract period. Service & Contract Procurement form contains the following information: a. Description of solicited services; b. Summary of written proposals; c. Basis for the selection of the vendor; d. If an emergency procurement for ongoing services, timeline for complete formal procurement process; and e. Date on which Board of Directors approved the service contract. 2. The entire management team received refresher training on the agency’s procurement policy on March 21, 2024; and 3. Management will solicit formal written proposals for professional accounting services by June 30, 2024.