The Organization concurs with the finding and acknowledges the need to improve its internal controls and procedures related to procurement and compliance with federal suspension and debarment requirements.
To address this, the Organization will revise its procurement policies to ensure that all pur...
The Organization concurs with the finding and acknowledges the need to improve its internal controls and procedures related to procurement and compliance with federal suspension and debarment requirements.
To address this, the Organization will revise its procurement policies to ensure that all purchases of goods or services charged to federal awards --including those exceeding the $10,000 threshold --are subject to proper competitive procurement practices, in accordance with 45 CFR 75.329 and 2 CFR 180. Clear documentation requirements will be established and enforced for all procurement decisions, including price comparisons, vendor selection criteria, and justification for sole-source procurement, where applicable.
Furthermore, the Organization will implement formal procedures to verify that all vendors are not suspended, debarred, or otherwise excluded from participation in federal programs. This will include performing and documenting verification against the System for Award Management (SAM.gov) prior to engaging vendors for federally funded procurements.
All relevant staff will receive targeted training on these updated procurement and compliance procedures to ensure consistent application across the Organization.
Organization Contact Person Responsible for Corrective Action:
Joseph Koehler, Director of Finance
Anticipated Completion Date: June 30, 2025