Finding Text
Criteria
Part 2, CFR 200, 200.318 states “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.”
Condition
While performing tests of the Garden’s internal controls over compliance, we noted the Garden had no procurement policy.
Cause of Condition
The Garden has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance.
Effect of Condition
Noncompliance may impact future funding from Federal awards.
Recommendation
We recommend the Garden implement proper internal control procedures including implementing and following a procurement policy in line with the Uniform Guidance.