Finding 1076222 (2023-002)

Identification of the federal program: 11.029 Tribal Broadband Grant Program Criteria: The grant agreement requires the grantee to follow competitive purchasing procedures that follow 2 CFR Part 200.317-326 for micro-purchase, small purchases, and formal procurements. Condition: The Cooperative was unable to provide documentation of the source selection methods used for all contracts, equipment, and material transactions greater than $10,000, and the Cooperative was unable to provide documentation of the procurement process used for all contracts, equipment, and material transactions greater than $250,000. Cause: The Cooperative did not maintain documentation of source selection methods or of the justification for noncompetitive procurements or contracts and did not have internal controls in place to ensure all required purchasing methods were followed. Effect: The Cooperative may be out of compliance with the procurement requirements of the grant. Competitive purchasing not being followed might result in higher costs incurred under the grant. Questioned Costs: None Recommendations: The Cooperative should implement processes and procedures to ensure competitive purchasing procedures are followed and all necessary documentation is maintained. Views of Responsible Officials: The Cooperative agrees with the finding above and will develop processes and procedures to ensure that, going forward, all pertinent documents and agreements are retained.