Audit 34952

Criteria: Non-federal entities are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance in 2 CFR sections 200.318 through 200.327 as well as verifying such contractors are not suspended, debarred or otherwise excluded pursuant to 31 CFR section 19.300. Condition: FamilyForward was selected to receive funds by the awarding entity in a non-competitive manner subsequent to the solicitation of bids for the construction of the campus for training and research on trauma informed care, which was the requirement per the contract. Accordingly, the procurement policies and procedures as well as the suspension and debarment procedures were not performed in accordance with Uniform Guidance. FamilyForward was determined to be uniquely qualified as a single feasible source as the only eligible entity to receive funds appropriated by the awarding entity. The construction vendor FamilyForward contracted with prior to the award of funds was not on the suspension and debarment list. FamilyForward provided a copy of the campus construction contract to the awarding entity as required prior to disbursement of funds. Effect: The competitive bidding procedures were performed at the subcontractor level by the general contractor however were not performed at the non-federal entity level. Cause: Award of funds was received after the contract agreements were solicited. Recommendation: While procurement processes appear to be completed, it does not appear procurement processes were completed was done under applicable Uniform Guidance. We recommend if grant funding is received for projects already in process, the procurement be discussed with the grantor and process/procedure be agreed upon to maintain compliance under the grant.

Criteria: Non-federal entities are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance in 2 CFR sections 200.318 through 200.327 as well as verifying such contractors are not suspended, debarred or otherwise excluded pursuant to 31 CFR section 19.300. Condition: FamilyForward was selected to receive funds by the awarding entity in a non-competitive manner subsequent to the solicitation of bids for the construction of the campus for training and research on trauma informed care, which was the requirement per the contract. Accordingly, the procurement policies and procedures as well as the suspension and debarment procedures were not performed in accordance with Uniform Guidance. FamilyForward was determined to be uniquely qualified as a single feasible source as the only eligible entity to receive funds appropriated by the awarding entity. The construction vendor FamilyForward contracted with prior to the award of funds was not on the suspension and debarment list. FamilyForward provided a copy of the campus construction contract to the awarding entity as required prior to disbursement of funds. Effect: The competitive bidding procedures were performed at the subcontractor level by the general contractor however were not performed at the non-federal entity level. Cause: Award of funds was received after the contract agreements were solicited. Recommendation: While procurement processes appear to be completed, it does not appear procurement processes were completed was done under applicable Uniform Guidance. We recommend if grant funding is received for projects already in process, the procurement be discussed with the grantor and process/procedure be agreed upon to maintain compliance under the grant.