Audit 387011

CRITERIA THE UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (UNIFORM GUIDANCE), SPECIFICALLY 2 CFR §200.317–200.327, REQUIRE NON-FEDERAL ENTITIES TO FOLLOW DOCUMENTED PROCUREMENT PROCEDURES THAT ENSURE FULL AND OPEN COMPETITION. WHEN USING COOPERATIVE OR COLLABORATIVE PROCUREMENT ARRANGEMENTS, THE DISTRICT MUST ENSURE THAT PURCHASES ARE MADE WITHIN THE VALID TERM OF THE UNDERLYING CONTRACT AND THAT CONTRACT EXTENSIONS OR RENEWALS ARE PERMITTED UNDER THE ORIGINAL PROCUREMENT AND PROPERLY EXECUTED. CONDITION THE DISTRICT CONTINUED TO PROCURE GOODS AND/OR SERVICES FROM A VENDOR THAT WAS ORIGINALLY AWARDED THROUGH A COLLABORATIVE PROCUREMENT AFTER THE EXPIRATION OF THE ORIGINAL BID TERM. THE CONTINUED USE OF THE VENDOR WAS NOT SUPPORTED BY A VALID CONTRACT EXTENSION OR REBID IN ACCORDANCE WITH PROCUREMENT REQUIREMENTS APPLICABLE TO FEDERAL AWARDS. AS A RESULT, PURCHASES CHARGED TO THE FEDERAL PROGRAM WERE MADE OUTSIDE THE ALLOWABLE TERM OF THE COMPETITIVELY PROCURED AGREEMENT. CAUSE MANAGEMENT DID NOT IMPLEMENT ADEQUATE PROCEDURES TO MONITOR THE EXPIRATION DATES AND ALLOWABLE TERMS OF COLLABORATIVE PROCUREMENT AGREEMENTS USED FOR FEDERAL EXPENDITURES. ADDITIONALLY, THE DISTRICT RELIED ON HISTORICAL PURCHASING PRACTICES WITHOUT VERIFYING ONGOING COMPLIANCE WITH UNIFORM GUIDANCE PROCUREMENT REQUIREMENTS. EFFECT THE DISTRICT DID NOT COMPLY WITH FEDERAL PROCUREMENT REQUIREMENTS, RESULTING IN EXPENDITURES THAT MAY NOT HAVE BEEN MADE UNDER FULL AND OPEN COMPETITION AS REQUIRED. THIS NONCOMPLIANCE INCREASES THE RISK THAT FEDERAL FUNDS WERE EXPENDED IN A MANNER INCONSISTENT WITH FEDERAL REGULATIONS. QUESTIONED COSTS NONE IDENTIFIED. THE PRICING WAS CONSISTENT WITH THE PRIOR CONTRACT TERMS. REPEAT FINDING NO. RECOMMENDATION WE RECOMMEND THAT MANAGEMENT STRENGTHEN PROCUREMENT CONTROLS BY: • IMPLEMENTING PROCEDURES TO TRACK CONTRACT AND BID EXPIRATION DATES, INCLUDING COLLABORATIVE PROCUREMENT AGREEMENTS; • ENSURING THAT ALL PROCUREMENTS CHARGED TO FEDERAL AWARDS ARE SUPPORTED BY VALID CONTRACTS WITHIN APPROVED TERMS; AND • PROVIDING TRAINING TO STAFF RESPONSIBLE FOR PROCUREMENT AND ACCOUNTS PAYABLE ON FEDERAL PROCUREMENT REQUIREMENTS.