Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the ...
Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with Build America, Buy America (BABA) Act. Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grantrequired stipulations such as BABA requirements, monitoring, compliance, and documentation. Anticipated completion date: We will develop and approve the updated procurement policy by 7/31/2026.