Audit 410228

Criteria: Pursuant to 2 CFR § 200.318, non-Federal entities must maintain documented procurement procedures that conform to applicable State, local, and organizational laws and regulations, as well as the standards identified in 2 CFR § 200.317 through § 200.327. Condition: The Center adopted a written procurement policy in July 2025. However, because the policy was not in effect for the majority of the audit period, the required procurement procedures (such as micro_x0002_purchase thresholds, mail purchase price/rate quotations, or formal competitive proposals) for vendor selections were not consistently performed or documented throughout the fiscal year. Effect of Condition and Questioned Costs: Because written procurement policies and control procedures were not in place for the full year, the Center cannot ensure that goods and services purchased with federal funds are acquired in a manner providing full and open competition, or that prices paid are reasonable. ● Sample Testing: Out of seven transactions tested, we identified seven transactions totaling $409,114 for which required procurement procedures were not performed or documented. ● Questioned Costs: Known questioned costs total $409,114 [exceeds the $25,000 threshold under 2 CFR § 200.516(a)(3)]. Cause: Management did not formally adopt written internal policies and procedures for procurement under federal awards until July 2025. Consequently, for most of the fiscal year, staff responsible for purchasing operated without formal guideless or training regarding federal compliance requirements. Recommendation: We recommend that management consistently enforce the written procurement policy adopted in July 21025 to ensure ongoing compliance with 2 CFR § 200.317 through § 200.327. Additionally, management should ensure all personnel involved in federal purchasing are trained on these requirements and implement controls to retain supporting documentation (such as vendor quotes, price comparisons, or sole-source justifications) for all federal procurements. View of Responsible Officials and Planned Corrective Action: The Center agrees with the finding. Management formally adopted a Uniform Guidance compliant procurement policy in July 2025, and training with provided to all staff. See the separate Corrective Action Plan for full details