Audit 327534

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions.Condition: During our testing over Procurement, Suspension & Debarment, we noted one instance where the Organization was unable to locate the procurement files to support the sole source justification for the procurement transaction along with not being able to locate documentation that the suspension and debarment check was performed prior to entering into a transaction with the vendor.Questioned costs: NoneContext: During our testing over Procurement, Suspension & Debarment, we noted one instance where the Organization was unable to locate the procurement files to support the sole source justification for the procurement transaction along with not being able to locate documentation that the suspension and debarment check was performed prior to entering into a transaction with the vendor.Cause: The Organization lacks established internal controls and procedures over financial grant management. The Organization did not maintain files related to the procurement process and suspension and debarment checks.Effect: Noncompliance results in possible Federal funds provided to ineligible vendors.Repeat Finding: No.Recommendation: We recommend that the Organization create an internal policy over the documentation of sole source/non-competitive bid justification prior to contracting with a vendor using federal funds as well as implementing a process to ensure suspension and debarment checks are performed and documentation to show that the checks were performed are retained.Views of responsible officials: The Chief Financial Officer (CFO) reviewed the procurement policy with the ROAMS Director. The CFO educated the ROAMS Director that the Organization will need to have a separate document on sole source justification and that a suspension and debarment check will need to be completed for every vendor used in either purchasing equipment or services. The CFO also sits on the governing board of the ROAMS program and will ensure the procurement policy is reminded when specific issues or approvals come to the governing board. The grant accountant will also give the CFO notice if equipment is being purchased or contracts entered into that are being paid out of federal grant funds and there is no attached separate documentation for sole source or documentation of check for suspension and disbarment.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions.Condition: During our testing over Procurement, Suspension & Debarment, we noted one instance where the Organization was unable to locate the procurement files to support the sole source justification for the procurement transaction along with not being able to locate documentation that the suspension and debarment check was performed prior to entering into a transaction with the vendor.Questioned costs: NoneContext: During our testing over Procurement, Suspension & Debarment, we noted one instance where the Organization was unable to locate the procurement files to support the sole source justification for the procurement transaction along with not being able to locate documentation that the suspension and debarment check was performed prior to entering into a transaction with the vendor.Cause: The Organization lacks established internal controls and procedures over financial grant management. The Organization did not maintain files related to the procurement process and suspension and debarment checks.Effect: Noncompliance results in possible Federal funds provided to ineligible vendors.Repeat Finding: No.Recommendation: We recommend that the Organization create an internal policy over the documentation of sole source/non-competitive bid justification prior to contracting with a vendor using federal funds as well as implementing a process to ensure suspension and debarment checks are performed and documentation to show that the checks were performed are retained.Views of responsible officials: The Chief Financial Officer (CFO) reviewed the procurement policy with the ROAMS Director. The CFO educated the ROAMS Director that the Organization will need to have a separate document on sole source justification and that a suspension and debarment check will need to be completed for every vendor used in either purchasing equipment or services. The CFO also sits on the governing board of the ROAMS program and will ensure the procurement policy is reminded when specific issues or approvals come to the governing board. The grant accountant will also give the CFO notice if equipment is being purchased or contracts entered into that are being paid out of federal grant funds and there is no attached separate documentation for sole source or documentation of check for suspension and disbarment.