Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Type: Significant deficiency in internal control over compliance and an instance of noncompliance with respect to procurement requirements. Federal program: AL# 21.027, Coronavirus State and Local Fiscal Recovery Funds. Criteria: The Organization is obligated to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 C.F.R. Part 200, of which paragraph 200.324(d) states that the cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used. Questioned costs: $9,684; calculated as vendor’s profit based on 20% of the actual construction cost of $48,420 per vendor invoices. Condition: The Organization entered into a cost plus a percentage of cost contract with a vendor for restoration services related to its Bend, Oregon location. Effect: The Organization was out of compliance with 2 C.F.R. § 200.324(d). Cause: The contract was signed on April 7, 2023. The contract does not directly stipulate that the Organization would be billed under a cost plus a percentage of cost method, however, per the progress billing invoices, it is clear that the Organization was billed at cost plus 20 percent. The Organization did not have sufficient internal controls in place to identify that the contract was billed under a cost plus a percentage of cost method. The total fee estimates were agreed to before commencement of the project and were not modified from the actual amount billed. Additionally, the contract does state any changes to the price of the contract are subject to written, signed change orders for pre-approval by the Organization. Prevalence: This is an internal control design deficiency and an instance of immaterial noncompliance resulting in questioned costs of $9,684. Repeat finding: No. Auditor’s recommendation: Modify internal control policies to disallow entering into any contract that will be paid with federal award funds billed as a cost plus a percentage of cost method and implement a policy to review applicable invoices in enough detail to identify if, in fact, not being billed under such an arrangement.
Reference Number: 2024-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The State’s procurement policy, Administrative Bulletin No. 3.5 – Procurement and Contracting Procedures, requires Vermont State agencies and departments to competitively procure goods and services which includes using a competitive bidding process and performing an analysis of the cost-effectiveness of the procurement. Per 2 CFR section 200.219, the non-Federal entity must conduct all procurement transactions in a manner providing full and open competition. Per 2 CFR section 200.324(a), the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Human Services (Agency) was unable to provide documentation that it competitively procured a contract nor that a cost analysis was performed. Context: For one of five contracts selected for testing, the Agency was unable to provide documentation that it conducted the procurement using full and open competition, nor that a cost analysis was performed. Cause: The Agency’s procedures were not sufficient to ensure that it maintained documentation that it had competitively procured a contract nor that a cost analysis was performed. Internal controls did not detect or prevent the errors. Effect: Failure to competitively procure a contract and perform a cost analysis could result in the Agency procuring goods or services that are not cost-effective nor in the best interest of the Agency or the program. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The State’s procurement policy, Administrative Bulletin No. 3.5 – Procurement and Contracting Procedures, requires Vermont State agencies and departments to competitively procure goods and services which includes using a competitive bidding process and performing an analysis of the cost-effectiveness of the procurement. Per 2 CFR section 200.219, the non-Federal entity must conduct all procurement transactions in a manner providing full and open competition. Per 2 CFR section 200.324(a), the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Human Services (Agency) was unable to provide documentation that it competitively procured a contract nor that a cost analysis was performed. Context: For one of five contracts selected for testing, the Agency was unable to provide documentation that it conducted the procurement using full and open competition, nor that a cost analysis was performed. Cause: The Agency’s procedures were not sufficient to ensure that it maintained documentation that it had competitively procured a contract nor that a cost analysis was performed. Internal controls did not detect or prevent the errors. Effect: Failure to competitively procure a contract and perform a cost analysis could result in the Agency procuring goods or services that are not cost-effective nor in the best interest of the Agency or the program. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The State’s procurement policy, Administrative Bulletin No. 3.5 – Procurement and Contracting Procedures, requires Vermont State agencies and departments to competitively procure goods and services which includes using a competitive bidding process and performing an analysis of the cost-effectiveness of the procurement. Per 2 CFR section 200.219, the non-Federal entity must conduct all procurement transactions in a manner providing full and open competition. Per 2 CFR section 200.324(a), the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Human Services (Agency) was unable to provide documentation that it competitively procured a contract nor that a cost analysis was performed. Context: For one of five contracts selected for testing, the Agency was unable to provide documentation that it conducted the procurement using full and open competition, nor that a cost analysis was performed. Cause: The Agency’s procedures were not sufficient to ensure that it maintained documentation that it had competitively procured a contract nor that a cost analysis was performed. Internal controls did not detect or prevent the errors. Effect: Failure to competitively procure a contract and perform a cost analysis could result in the Agency procuring goods or services that are not cost-effective nor in the best interest of the Agency or the program. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The State’s procurement policy, Administrative Bulletin No. 3.5 – Procurement and Contracting Procedures, requires Vermont State agencies and departments to competitively procure goods and services which includes using a competitive bidding process and performing an analysis of the cost-effectiveness of the procurement. Per 2 CFR section 200.219, the non-Federal entity must conduct all procurement transactions in a manner providing full and open competition. Per 2 CFR section 200.324(a), the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Human Services (Agency) was unable to provide documentation that it competitively procured a contract nor that a cost analysis was performed. Context: For one of five contracts selected for testing, the Agency was unable to provide documentation that it conducted the procurement using full and open competition, nor that a cost analysis was performed. Cause: The Agency’s procedures were not sufficient to ensure that it maintained documentation that it had competitively procured a contract nor that a cost analysis was performed. Internal controls did not detect or prevent the errors. Effect: Failure to competitively procure a contract and perform a cost analysis could result in the Agency procuring goods or services that are not cost-effective nor in the best interest of the Agency or the program. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-014 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/3/2021 – 12/31/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The State’s procurement policy, Administrative Bulletin No. 3.5 – Procurement and Contracting Procedures, requires Vermont State agencies and departments to competitively procure goods and services which includes using a competitive bidding process and performing an analysis of the cost-effectiveness of the procurement. Per 2 CFR section 200.219, the non-Federal entity must conduct all procurement transactions in a manner providing full and open competition. Per 2 CFR section 200.324(a), the non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Administration (Agency) was unable to provide documentation that it competitively procured a contract nor that a cost analysis was performed. Context: For one of seven contracts selected for testing, the Agency was unable to provide documentation that it conducted the procurement using full and open competition, nor that a cost analysis was performed. The contract was procured in June 2020 in an initial amount of $5,000,000. Cause: The Agency’s procedures were not sufficient to ensure that it maintained documentation that it had competitively procured a contract nor that a cost analysis was performed. Internal controls did not detect or prevent the errors. Effect: Failure to competitively procure a contract and perform a cost analysis could result in the Agency procuring goods or services that are not cost-effective nor in the best interest of the Agency or the program. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding.
CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendor –– Beaver Valley Intermediate Unit ($332,200). This is a repeat procurement finding from (2023-005) from the previous fiscal year.CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, or 4) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). QUESTIONED COST: $332,200 RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs, 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.318(i) of the Uniform Guidance regarding maintaining records sufficient to detail the history of procurement which includes rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price, 4) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 5) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding, and 5) Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000). VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan