Finding 1076167 (2023-001)

U.S. Department of Education, Congressionally Funded Community Projects, Assistance Listing Number 84.215K – Internal Control Over Compliance and Compliance Over Written Policies – Procurement Compliance Requirement Criteria: As defined in 2 CFR 200.318, a recipient of federal grant funding must have and use its own documented procurement procedures for the acquisition of property or services required under a Federal or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317-327. Condition: During our audit, we were advised that while management used the Federal procurement standards at 2 CFR 200.317-327 in making all applicable decisions, the Foundation did not have written procurement policies tailored to the organization’s unique systems and processes. Cause: The Foundation’s risk assessment and internal control processes did not identify the requirement for written procurement procedures tailored to the organization’s unique systems and processes. Effect: Without written procurement procedures tailored to the organization's unique systems and processes, there is a risk that the staff and consultants responsible for ensuring compliance with the Foundation’s procurement policies will not be aware of proper procedures. Repeat Finding: No Recommendation: We recommend that management develop written procurement procedures tailored to the Foundation’s unique systems and processes that conform to the procurement standards identified in 2 CFR 200.317-327. Views of responsible officials and planned corrective actions: Written procurement procedures have been written for the Nevada Test Site Historical Foundation to ensure that procurements will be processed in conformity with 2 CFR 200.317 to 327. These procedures will be followed for procurements related to grants awarded to the entity. The dollar amount of the grant will determine the process to follow to be in compliance. Implementation of these changes will begin as of the date of this writing