Audit 408130

Criteria:The non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Internal controls should be designed to safeguard federal funds, ensure transactions are properly authorized and documented, and promote compliance with applicable federal requirements.Condition:The Board did not maintain formal written procurement policies and procedures designed to ensure compliance with Uniform Guidance requirements related to procurement, suspension, and debarment for federal awards. Specifically, the Board had not formally adopted policies addressing procurement methods, contract administration, suspension and debarment verification procedures, or documentation requirements applicable to federally funded expenditures.Cause and effect:The Board had not established or implemented formal written policies and procedures to address federal procurement compliance requirements under Uniform Guidance. The absence of formal procurement policies and procedures increases the risk that procurements funded with federal awards may not comply with Uniform Guidance requirements, including the risk that vendors subject to suspension or debarment could be improperly utilized and that procurements may not be adequately documented or competitively procured.Recommendation:The Board formally adopts written procurement policies and procedures consistent with Uniform guidance requirements under 2 CFR Part 200, including procedures addressing procurement methods, documentation standards, contract oversight, and suspension and debarment verification requirements.Management’s response: The Board acknowledges the finding and is in the process of implementing procedures to address the items noted.