Finding Text
Finding No.: 2023-001 Procurement
Federal Agency: National Endowment for the Humanities
Federal Assistance Listing No.: 45.129
Program: Promotion of the Humanities-Federal State Partnership
Requirement: Procurement, Suspension and Debarment
Type of Finding: Significant Deficiency
Federal award no. and year: SO-283113-22
Criteria: 2 CFR 200.319 requires all procurement transactions to be conducted in a manner providing full and open competition.
The Council’s purchasing and procurement policy requires the Council to obtain and evaluate competitive bids to determine the vendor with the optimal qualities including price, availability, and quality, among other factors; and the documentation of this process.
Condition: The Council did not maintain documentation within 1 procurement file to demonstrate that the procurement was conducted in a manner providing full and open competition.
Context: We selected a non-statistical sample of 2 procurement transactions out of a population of 6
procurement transactions, and noted that the procurement file for 1 of our selections included
documentation of the significant history of the procurement transaction, however was missing specific documentation to evidence that the procurement was conducted in a manner providing full and open competition.
Cause: The Council has adopted a purchasing and procurement policy which requires documentation of each procurement transaction to support that it was conducted in a manner providing full and open
competition, however the Council was not diligent in following this policy.
Effect: Failure to properly adhere to the purchasing and procurement policy resulted in a lack of evidence to support that a procurement transaction was conducted in a manner providing full and open competition.
Questioned costs: None
Identification of a repeat finding: N/A
Recommendations: The Council should diligently follow its existing policy.
Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. See Corrective Action Plan.