Federal Program: ALN 93.600 Head Start Category: Compliance/internal control significant deficiency Compliance Requirement: Equipment and real property management Criteria: 2 CFR §200.313 (d) establishes that in the management requirements of equipment that regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient or subrecipient must manage equipment (including replacement equipment) utilizing procedures that meet the following requirements: (1) Property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the Federal Award Identification Number), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. As established by BGCPR's capitalization policy, all items with a unit cost exceeding $5,000 must be capitalized. As per 2 CFR §200.1 equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $5,000 on June 30, 2025. Condition: BGCPR real and personal property records are not complete and did not follow the program requirements. BGCPR’s fixed asset records include assets acquired using multiple funding sources (federal, state, and private). However, the BGCPR has not implemented a mechanism to clearly identify and distinguish equipment acquired with federal funds within the fixed asset system. As a result, property records for federally funded equipment are incomplete and do not include all data elements required under 2 CFR §200.313(d)(1), including Federal Award Identification Number (FAIN), percentage of federal participation, and information related to location, use, condition, and disposition. In addition, certain equipment acquisitions that exceeded BGCPR’s capitalization threshold were not capitalized in the fixed asset records. Cause: BGCPR did not maintain essential details, such as acquisition costs, funding sources, or the federal award identification numbers. In addition, management did not consistently apply its capitalization policy. Effect or potential effect: As a result of this condition, BGCPR: • Is not in compliance with 2 CFR §200.313(d)(1); • May incur questioned or disallowed costs related to federally funded equipment • Cannot readily identify federally funded equipment for monitoring, reporting, or physical inventory purposes • Is exposed to an increased risk of loss, misuse, or inaccurate reporting of federally funded equipment, which may affect current and future federal funding. Questioned costs: Amount is below the threshold to be considered a questioned cost. Context: Upon testing a sample of twenty one (21) assets, we noted that two (2) equipment acquisitions exceeding the capitalization threshold were not capitalized, four assets lacked an Asset ID identification or tag number, and one asset lacked a serial number. Identification as a repeat finding: As of June 30, 2024, finding 2024-007 was identified under this condition. This finding is still valid for the year ended June 30, 2025. Recommendation: BGCPR must identify all properties acquired with Federal funds and maintain adequate accounting records in accordance with Federal regulations. The program must maintain an automated accounting and record keeping system adequate for effective oversight. Management should strengthen its fixed asset tracking system to ensure compliance with 2 CFR §200.313(d)(1) by: • Implementing a method to clearly identify and track equipment acquired with federal funds within the fixed asset register; • Updating property records to include all required data elements (e.g., FAIN, percentage of federal participation, location, condition, and disposition data) for federally funded equipment; • Establishing formal policies and procedures for recording, monitoring, and disposing of equipment acquired with federal funds; • Performing periodic reviews and physical inventories to ensure completeness and accuracy of federally funded equipment records. Views of officials responsible: BGCPR recognizes that it must keep and improve the asset capitalization processes and policies, particularly within the accounting system of record. It acknowledges the need to strengthen these processes to ensure accurate and compliant management of equipment acquisitions. To address this, during fiscal year 2025-26, BGCPR implemented a system capable of recording, classifying, and monitoring all capital assets in alignment with the criteria established under federal regulation 2 CFR §200. This improvement is essential to ensure that all asset capitalization activities meet regulatory standards and support greater financial transparency and accountability. As a corrective measure, BGCPR will take the following actions: a. A property and inventory coordinator was hired and is responsible for overseeing all aspects of property control and asset management. b. Full Implementation Property software to accurately all property of by BGCPR. The system includes information such as asset identification number, acquisition date, funding source, cost, useful life, depreciation, location, and other relevant details, serving as a support tool for the property records maintained in the accounting system. c. Prepare an updated Property Control Manual, which is pending final approval by senior management. Implement procedures for timely recording of acquisitions, transfers, disposals, and impairments to ensure that asset records remain current and accurate. d. Perfom and complete physical inventory for all Units and Central Office. e. All inventory counts have been entered into the system. f. All property acquired have been recorded in the property software. g. Currently we are in the process of valuation of the physical inventory to reconcile with the accounting records by December 31, 2026. h. Training was provided to personnel involved in asset management and inventory activities to ensure consistent application of established procedures. i. Perform periodic monitoring reviews by finance, compliance, or internal audits to validate adherence to property control policies and inventory requirements. Anticipated Completion Date: December 31, 2026
Federal Program: ALN 10.536 CACFP Training Grants ALN 93.575 Child Care and Development Block Grant (CCDBG) ALN 93.600 Head Start Category: Compliance/Internal control significant deficiency Compliance Requirement: Reporting Criteria: 2 CFR §200.512 (a) (1) establishes that the audit must be completed, and the data collection form and reporting package must be submitted within the earlier 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition: BGCPR did not submit the required data collection form and reporting package for the year ended June 30, 2025, within the required period. Cause: BGCPR did not have available the financial information necessary to complete the audit procedures and single audit reporting package. Effect or potential effect: Condition may result in noncompliance with the requirements for Reporting. Recommendation: We recommend management establish calendars to ascertain submission of data collection form and reporting package within the required dates. Identification as a repeat finding: As of June 30, 2024, finding 2024-010 was identified under this condition. This finding is still valid for the year ended June 30, 2025. Views of responsible officials: BGCPR acknowledges that the delay in the preparation and submission of its audited financial statements was influenced by several interrelated factors, primarily stemming from the challenges associated with a transitional period and the unexpected resignation of the Chief Financial Officer (CFO). The absence of a key financial executive during this period significantly impacted on BGCPR’s ability to compile, review, and finalize the required financial documentation in accordance with established timelines. As a result, BGCPR was unable to meet the statutory deadlines for submitting the audited financial statements, including the data collection form and the complete reporting package, thereby resulting in non-compliance with applicable legal and regulatory reporting requirements. Recognizing the importance of timely and accurate financial reporting, BGCPR is committed to implementing corrective measures. These include the development and enforcement of a structured reporting calendar, the allocation of dedicated resources to support audit preparation, and the establishment of internal checkpoints to monitor progress. These actions are intended to ensure that future submissions are completed within the required deadlines, thereby restoring compliance and reinforcing BGCPR’s commitment to transparency and accountability. As a corrective measure, BGCPR will take the following actions: a. Developing and enforcing a structured reporting calendar; b. Allocating dedicated resources to support audit preparation; c. Establishing internal checkpoints to monitor progress and ensure accountability; d. Ensure future submissions meet the required deadlines. Anticipated completion date: December 31, 2026
Federal Program: ALN 14.218-CDBG-DR/Entitlement Grant Category: Compliance/internal control significant deficiency Compliance requirement: Equipment and real property management Criteria: BGCPR Finance Policies to administer CDBG-DR funds, established by the Puerto Rico Department of Housing in Chapter 15, Section 2, require that sub-recipients must capitalize property and equipment with a cost of $500 or more. Condition: The capitalization threshold used for property and equipment acquired with CDBG funds is not in compliance with Finance Policies to administer CDBG-DR funds, as established by the Puerto Rico Department of Housing. Cause: The capitalization policy followed by BGCPR, with the exception of CDBG funds, is to capitalize property and equipment with a cost of $5,000 or more. Questioned costs: Amount is below the threshold to be considered a questioned cost. Effect or potential effect: Property and equipment acquired with CDBG-DR funds is being expensed instead of capitalized. Context: Two (2) instances of property and equipment acquired with CDBG-DR funds were not recorded in the equipment details, resulting in the assets being expensed instead of capitalized as required by the Finance Policies to administer CDBG-DR funds. Identification as a repeat finding: As of June 30, 2024 and June 30, 2023, this condition was associated with findings 2024-009 and 2023-002. Recommendation: We recommend that management updates its capitalization policy to include this specific requirement for property and equipment acquired with CDBG-DR funds. Views of officials responsible: BGCPR acknowledges a significant oversight in the financial management of assets acquired with Community Development Block Grant – Disaster Recovery (CDBG-DR) funds. Specifically, it has been identified that certain property and equipment purchased using these funds were not properly recorded in the equipment detail ledger. As a result of this omission, these assets were incorrectly treated as expenses in the financial records, rather than being capitalized in accordance with BGCPR’s established financial policies and the federal guidelines governing the administration of CDBG-DR funds. This misclassification not only affects the accuracy of BGCPR’s financial statements but also represents a deviation from required asset management practices, which mandate the capitalization and tracking of equipment to ensure accountability, proper depreciation, and compliance with grant conditions. As a corrective measure, BGCPR will take the following actions: a. BGCPR will implement a corrective action plan to strengthen accounting processes related to account registration and equipment capitalization related to the CDBG-DR; b. Procurement procedures for requesting, approving, and accepting goods and services, Include agency consultation; c. Ensure accuracy in financial records that Maintain compliance with applicable regulations; d. Account for taxes and support service costs (e.g., installation, delivery); e. Ensure all purchases align with federal regulations. Anticipated Completion Date: December 31, 2026
Federal Program: ALN 93.575 Child Care and Development Block Grant (CCDBG) Category: Compliance/Internal control significant deficiency Compliance requirement: Reporting Criteria: In accordance with 2 CFR § 200.328, “the recipient or subrecipient must submit financial reports as required by the Federal award”. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. For the ALN 93.575 and in accordance with clause 9.1 J of the agreement with the awarding agency, requirements for processing subsequent fund requests establish that such requests must be submitted during the first fifteen (15) calendar days of each quarter that includes the fund request (CC-004); prior quarter cumulative expense report (CC-003); list of outstanding obligations; certified payroll (with full employee names) for reported months; and bank reconciliations (CC-005) with statements, copies of checks, and invoices for expenses ≥ $100. Although the 2 CFR § 200.328 allows up to 30 days for submission, the subaward agreement establishes a more restrictive deadline of 15 calendar days, which governs compliance for BGCPR. Condition: Quarterly reports were not submitted in a timely manner. Context: Two (2) of the four (4) quarterly reports were not submitted in a timely manner. Cause: BGCPR did not have available financial information necessary to complete the reports on a timely matter Effect or potential effect: The reports being submitted late and non-compliance with reporting requirements. Recommendation: We recommend that BGCPR enhance onboarding and transition procedures for key personnel, including formal training, documented reporting processes, and automated deadline tracking, to ensure timely submission of required reports Views of officials responsible: We recognize that due to the volume of report and transaction, these two reports were not issued as required. Steps have been taken to avoid this situation happening in the future, which includes preparing schedule reports, establishing datelines and hiring additional finance personnel to work with the required reports. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.600-Head Start Category: Compliance/Internal control significant deficiency Compliance Requirement: Reporting Criteria: In accordance with 2 CFR §§ 200.328(c) and 200.329(a), recipients are required to submit reports required by the Federal award within the prescribed timeframes and maintain adequate monitoring procedures to ensure compliance with all applicable Federal requirements. In accordance with 45 CFR § 75.343, non-Federal entities are required to submit reports at least annually on the status of real property in which the Federal Government retains an interest. Accordingly, Head Start grantees, including those with no covered real property to report, are required to submit the SF-429 Real Property Status Report and SF-429 Attachment A annually by the due date. Condition: The SF-429 Real Property Status Report was not submitted within the required due date. Cause: Turnover of key personnel responsible for preparing and/or reviewing the report. Questioned cost: No real property was included under the Head Start award 02CH012049; therefore, no questioned costs were identified. Effect or potential effect: The reports being submitted late and in non-compliance with reporting requirements. Recommendation: We recommend that BGCPR enhance onboarding and transition procedures for key personnel, including formal training, documented reporting processes, and automated deadline tracking, to ensure timely submission of required reports Views of officials responsible: Due to the BCPR’s transition period, the reports were submitted late. After the new Finance Director started in June 25, 2025. On January 30, 2026, we received system access, all reports were submitted on February 4, 2026. This matter was presented in the most recent focus Area II monitoring by the Agency, with no complaints noted. We will request additional system access for reporting purposes in case the person responsible is unavailable. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.575 Child Care and Development Block Grant (CCDBG) Category: Compliance Compliance requirements: Allowable Costs / Cost Principles Record retention Condition: BGCPR did not maintain sufficient documentation to demonstrate compliance with minimum personnel qualification requirements. Criteria: Pursuant to 2 CFR §200.430(a)(2), costs of compensation are allowed only to the extent that the total compensation for individual employees follows an appointment made in accordance with the recipient's or subrecipient's laws, rules, or written policies Additionally, 2 CFR §200.303(a) requires recipients and subrecipients to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Further, 2 CFR §200.403(g) requires costs charged to Federal awards to be adequately documented. Moreover, pursuant to 2 CFR §200.334, recipients and subrecipients must retain all Federal award records, including financial records, supporting documentation, and statistical records, for a minimum of three years from the date of submission of the final financial report. If litigation, claims, or audit findings are initiated before the expiration of the retention period, the records must be retained until all such matters are resolved and final action has been taken. Context: During testing of four payroll-related transactions selected for Allowable Activities and Allowable Costs compliance testing, we noted that one sampled employee did not meet the minimum educational and experience qualifications established for the position. Cause: For one payroll-related item, the personnel file did not contain documentation demonstrating that the employee met the minimum educational and experience qualifications established for the position. The employee did not possess the required bachelor's degree at the time of promotion. Although management subsequently provided an undated narrative explaining the basis for the hiring decision, no supporting documentation evidencing an approved exception at the time of promotion was maintained in the personnel file. Questioned cost: Amount is below the threshold to be considered a questioned cost. Effect or potential effect: As a result, BGCPR could not demonstrate that the employee's appointment was made in accordance with its established hiring requirements. Consequently, compensation costs charged to the Federal award may not be fully supported as allowable. Recommendation: Ensure personnel files contain documentation demonstrating that employees meet the minimum qualifications for their positions and retain evidence of any approved exceptions or waivers supporting hiring or promotion decisions. Views of officials responsible: BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.575 Child Care and Development Block Grant (CCDBG) Category: Compliance Compliance requirements: Allowable costs Record retention Condition: The BGCPR did not maintain sufficient documentation to demonstrate compliance with employee background check requirements. Criteria: Pursuant to 2 CFR §200.430(a)(2), compensation costs are allowable when appointments are made in accordance with the recipient's written policies and procedures. Further, 2 CFR §200.303(a) requires recipients to establish and maintain effective internal controls to ensure compliance with applicable requirements. Additionally, 2 CFR §200.403(g) requires costs charged to Federal awards to be adequately documented. Moreover, pursuant to 2 CFR §200.334, recipients and subrecipients must retain all Federal award records, including financial records, supporting documentation, and statistical records, for a minimum of three years from the date of submission of the final financial report. If litigation, claims, or audit findings are initiated before the expiration of the retention period, the records must be retained until all such matters are resolved and final action has been taken. Per the BGCPR Human Resources Policies and Procedures Manual, specifically the Required Certifications and Background Check Policy, all employees and leaders must maintain current required certifications and documentation, including Criminal Record Certificate, Health Certificate, Law 300 Certificate, Educational Credentials, and Fingerprint Verification, and must successfully complete applicable background checks before perform their duties. Failure to comply with these requirements may result in restrictions from performing job responsibilities and may affect continued employment. Context: We found that two (2) of the four (4) sample employees lacked documentation, evidencing compliance with BGCPR's required background check procedures. Cause: For two (2) payroll-related items, the personnel files did not contain evidence demonstrating that required background checks had been completed in accordance with the BGCPR's hiring policies. For one employee, the background check was performed after the employee's recruitment date. For the second employee, the required background check documentation was not available in the personnel file at the time of the audit. Although management subsequently provided the documentation after the exception was identified, the evidence indicated that the background check report was printed in July 2026. Accordingly, the personnel files did not contain sufficient documentation to support compliance with the BGCPR's background check requirements during the audited period. Questioned cost: Amount is below the threshold to be considered a questioned cost. Effect or potential effect: As a result, BGCPR could not demonstrate that the employees were hired in accordance with established hiring requirements or that compensation costs charged to the Federal award were supported by adequate documentation. Recommendation: Ensure personnel records are complete, accurate, and maintained in accordance with established policies and procedures Views of officials responsible: BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.600 Head Start Program ALN 10.536 CACFP Training Grants Category: Compliance/ internal control significant deficiency Compliance requirements: Procurement and Suspension/Debarment Condition: BGCPR did not document or maintain evidence of the required SAM.gov vendor eligibility verifications for procurement transactions charged to federal programs. Criteria: Pursuant to 2 CFR § 200.214 and 2 CFR § 180.300, recipients and subrecipients may not enter into covered transactions with parties that are debarred, suspended, or otherwise excluded from participation in Federal awards and must verify that vendors are not excluded or disqualified by checking SAM.gov exclusions, obtaining a certification, or including an appropriate contractual clause. BGCPR Fiscal Policies and Procedures, under the Cash Disbursements and Cash Allocations policies, require that all vendors be verified through the System for Award Management (SAM.gov) prior to establishing a commercial relationship and before disbursing funds. Cause: Although BGCPR's Fiscal Policies and Procedures require verification of vendors through SAM.gov prior to establishing a commercial relationship and before disbursing Federal funds, management did not consistently adhere to these established policies and procedures. As a result, vendor eligibility reviews were not performed or documented as required. Context: For 17 of 21 transactions tested, BGCPR did not perform or maintain documentation evidencing that vendors were verified through SAM.gov prior to entering into covered transactions, as required by Federal regulations. Consequently, BGCPR could not demonstrate that the vendors were not suspended, debarred, or otherwise excluded from participation in Federal programs at the time the transactions were executed. Questioned cost: None identified. During our audit procedures, we found no evidence indicating that the vendors tested were suspended, debarred, or otherwise excluded from participation in Federal programs. However, because the required verification was not performed or documented at the time of the transactions, compliance could not be demonstrated. Effect or potential effect: The failure to perform and document SAM.gov searches increase the risk that federal funds could be expended on transactions with vendors that are suspended, debarred, or otherwise excluded from participation in federal programs, resulting in noncompliance with federal procurement requirements. Recommendation: We recommend that management strengthen its procurement policies and procedures to require documented verification of all applicable vendors through SAM.gov before awarding contracts or making purchases with federal funds. Evidence of the verification should be retained in the procurement file and periodically monitored for compliance. Views of officials responsible: We acknowledge that internal control should be strengthened by reviewing the current BGCPR Fiscal Policy, and effective September 30, 2026, all vendors must be verified who are not excluded or disqualified at System for Award Management (SAM.gov). This verification will be incorporated into the Workflow system and maintained as part of the vendor approval process. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.600 Head Start Program Category: Compliance/ internal control significant deficiency Compliance requirements: Procurement and Suspension/Debarment Condition: BGCPR did not follow its procurement policies in compliance with applicable State and Federal procurement requirements. Criteria: BGCPR’s Fiscal Policy Manual — VI. Cash Disbursements & Expense Allocations, Incoming Invoice Processing, item 2 established that vendors must be created in the Workflow system in accordance with established procedures. Documentation for new vendors must be obtained and reviewed for completeness and accuracy and must include, at a minimum, Form W-9, the new vendor form, and a valid Merchant Registration Certificate issued by the applicable local governmental agency. 2 CFR § 200.318(a) requires recipients and subrecipients to maintain and use documented procurement procedures for procurement transactions under a Federal award or subaward, including the acquisition of property or services. These procedures must be consistent with applicable State, local, and tribal laws and regulations and the Federal procurement standards. 2 CFR § 200.318(h) requires recipients and subrecipients to award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration must be given to contractor integrity, public policy compliance, proper classification of employees, past performance, and financial and technical resources. 2 CFR § 200.318(i) requires recipients and subrecipients to maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Under 2 CFR § 200.319(a), procurement transactions must provide full and open competition. When simplified acquisition procedures apply, § 200.320(a)(2)(i) requires price or rate quotations from an adequate number of qualified sources; noncompetitive procurement is permitted only under the circumstances in § 200.320(c) and must be supported by the procurement record. Under 2 CFR § 200.214 and Appendix II(H) to Part 200, contract awards must not be made to parties that are debarred, suspended, or otherwise excluded in SAM. Section 200.327 requires contracts under Federal awards to contain the applicable provisions in Appendix II. Cause: BGCPR did not consistently apply its procurement policies and did not have an effective pre-award and supervisory review control to confirm vendor eligibility, required competition and approvals, complete procurement documentation, and applicable contract provisions before purchase commitments and payments were made. Context: Of 21 procurement transactions tested: 7 samples did not have an available supplier merchant registration certificate; 5 samples did not evidence the required quotation process and/or purchase order and did not include a documented justification; and 3 samples had contracts of which 2 samples did not include a debarment and suspension provision. Effect or potential effect: The absence of required vendor documentation, competition support, purchase orders or documented justification, and debarment and suspension controls increases the risk that purchases may be made from unauthorized or excluded vendors, may not provide full and open competition, and may be unsupported or subject to questioned costs under the Federal award. Recommendation: We recommend that management strengthen and enforce procurement controls by: (1) requiring a current Puerto Rico Merchant Registration Certificate before award or purchase; (2) documenting the required quotations and purchase order, or an approved justification citing the allowable basis for a noncompetitive procurement; (3) performing and retaining a dated SAM.gov exclusion search before contract award and renewal; (4) using standardized contracts containing all applicable Federal provisions, including debarment and suspension language; and (5) requiring documented supervisory review of a procurement checklist before approval and payment. Views of officials responsible: BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Anticipated completion date: September 30, 2026
Federal Program: ALN 10.536 CACFP Training Grants Category: Compliance/internal control significant deficiency Compliance requirements: Allowable costs / cost principles/procurement Record retention Condition: The procurement process was not adequately documented to demonstrate compliance with BGCPR's procurement policy. Criteria: 2 CFR § 200.318(a) requires recipients and subrecipients to maintain and use documented procurement procedures for procurement transactions under a Federal award or subaward, including the acquisition of property or services. These procedures must be consistent with applicable State, local, and tribal laws and regulations and the Federal procurement standards. 2 CFR § 200.318 (e) established that when appropriate for the procurement or use of common or shared goods and services, recipients and subrecipients are encouraged to enter into State and local intergovernmental agreements or inter-entity agreements for procurement transactions. These or similar procurement arrangements using strategic sourcing may foster greater economy and efficiency. Documented procurement actions of this type (using strategic sourcing, shared services, and other similar procurement arrangements) will meet the competition requirements of this part. 2 CFR § 200.318 (i) established that the recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. According to VI. Purchasing and Procurement of the BGCPR’s Fiscal Policies and Procedures, all requisitions, purchase orders, and invoices must be approved prior to the purchase commitment. For purchases between up to $1,000, quotations are not required; however, the Purchasing Department must obtain price information from the supplier. Every transaction should have a formal purchase order from BGCPR’s system. Further, 2 CFR §200.403(g) requires costs charged to Federal awards to be adequately documented. Moreover, pursuant to 2 CFR §200.334, recipients and subrecipients must retain all Federal award records, including financial records, supporting documentation, and statistical records, for a minimum of three years from the date of submission of the final financial report. If litigation, claims, or audit findings are initiated before the expiration of the retention period, the records must be retained until all such matters are resolved and final action has been taken. Context: For 2 samples tested, purchases were made without a formal purchase order generated from the system. In addition, 1 sample included merchandise received and paid in excess of the amount authorized in the purchase order. The purchase order was not amended. Cause: Program procurement personnel relied on the pass-through entity's procurement process and did not consistently maintain documentation required under BGCPR's internal procurement policy. Questioned cost: Amount is below the threshold to be considered a questioned cost. Effect or potential effect: Failure to consistently follow the entity’s procurement policy may result in unsupported or unauthorized purchases, payments exceeding approved amounts, and questioned costs if the expenditures are not properly authorized, documented, or determined to be allowable. Recommendation: Management should strengthen oversight of procurement activities and ensure that all procurement transactions are supported by documentation demonstrating compliance with BGCPR's procurement policies, including the use of formal purchase orders and adherence to authorized purchasing limits. Views of officials responsible: In order to avoid this situation happening in the future, instruction will be provided to all personnel emphasizing that every purchase should be made through a purchase order. This will ensure that we follow the BGCPR formal procedure and ensure better internal control is being followed. In addition, we will emphasize that no shipment should be received if such purchase is not in accordance with the specification disclosed in the purchase order. Anticipated Completion Date: September 30, 2026