Identification Number: 2024-001
Finding: Procurement, Suspension and Debarment
Corrective Actions Taken or Planned:
The Armed Services YMCA (ASYMCA) acknowledges the control deficiency identified in the area of procurement policy and is actively addressing it to ensure full compliance with 2 CFR § ...
Identification Number: 2024-001
Finding: Procurement, Suspension and Debarment
Corrective Actions Taken or Planned:
The Armed Services YMCA (ASYMCA) acknowledges the control deficiency identified in the area of procurement policy and is actively addressing it to ensure full compliance with 2 CFR § 200.318 (formerly referenced as 2 CFR 300.218), which governs procurement standards for non-federal entities receiving federal awards.
1. Policy Development and Alignment with Federal Regulations
ASYMCA Finance is currently compiling and formalizing procurement procedures in accordance with 2 CFR § 200.318. This initiative will result in a comprehensive, board-approved procurement policy that ensures compliance with federal requirements and strengthens internal controls.
2. Existing Policies and Controls
ASYMCA already maintains consistent, documented, and approved policies in several key areas of procurement and financial management, including:
• Authority of Responsibility: Delegation of authority for designating funds and obligating ASYMCA for purchases, including spending thresholds and approved personnel.
• Procurement Standards: General procurement principles and internal controls.
• Professional Services and Consulting Agreements
• Purchase of Capital Items
• Signature Authority
• Legal Review
• Unbudgeted Expenditures
• Record Retention
• Policy Enforcement and Consequences
• Procedures for Invoicing, Payment Processing, and Reimbursements (Travel and Non-Travel)
• Requesting New Vendors
• Competition: Requirements for full and open competition in vendor selection.
3. Areas for Expansion and Integration
To ensure full compliance with federal procurement standards, ASYMCA will expand its current policies to include the following areas:
• Conflict of Interest: Clear guidelines to prevent personal or organizational conflicts in procurement decisions.
• Methods of Procurement: Defined procedures for micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals.
• Purchase/License of Technology or Software: Standards for evaluating and acquiring digital tools and platforms.
• Indirect Cost: Clarification of treatment and allocation of indirect costs in procurement.
• Methods of Procurement (as per federal thresholds)
• Contracting with Small and Minority Businesses and Women’s Business Enterprises
• Contract Cost and Price Analysis
• Federal Awarding Agency Requirements
4. Implementation Timeline
ASYMCA is committed to finalizing, approving, and implementing the updated procurement policy the end of the 2025 reporting period. This will include:
• Internal review and legal vetting (if necessary)
• Board and/or Audit Committee approval
• Staff training and dissemination of the policy
• Integration into operational procedures for all federally funded and non-federally funded projects
Conclusion
ASYMCA is committed to maintaining the highest standards of accountability, transparency, and regulatory compliance. The actions outlined above demonstrate a proactive and structured approach to addressing the control deficiency and ensuring that all procurement activities are conducted in accordance with applicable federal regulations.
Anticipated completion date: December 31, 2025
Responsible Contact Person: Laura Tate-Smith, Chief Financial Officer