Audit 390569

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 Organizations should have internal controls designed to ensure compliance with these provisions Condition and Context During our testing over Procurement and Suspension and Debarment, noted the Organizations did not have procedures or controls in place to adequately maintain documentation that bids were obtained for procurement transactions. During our testing over Suspension & Debarment, noted one instance in which the Organizations did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds being paid to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks a uniform procurement policy that is in compliance with the federal regulations and/or the terms and conditions of the federal award. Recommendation We recommend the Organizations review the procurement policy to ensure it is in line with federal regulations and implement a process to ensure that documentation for bids and sole-source transactions are retained in the Organizations records. Additionally, we recommend the Organization review their process of performing suspension and debarment checks prior to entering into transactions with vendors to ensure all vendors are included in the monthly checks. Views of Responsible Officials Effective February 2026, the Organizations amended and strengthened its existing procurement policy through the implementation of an enterprise-wide Finance Procurement and Vendor Compliance Policy. This updated policy: • Standardizes procurement documentation requirements for all vendors; • Requires documented bid/quote retention and sole-source justification consistent with Uniform Guidance; • Mandates System for Award Management (SAM.gov) verification prior to vendor onboarding and payment; • Centralizes responsibility for exclusion screening and procurement documentation within Accounts Payable and Supply Chain, under CFO oversight; and • Establishes uniform retention and audit-readiness standards. These controls are supported by standardized checklists, documented workflows, and retention requirements, all of which are cross-referenced within the Organizations Finance Policies and Procedures Manual. The policy is fully implemented and operational.