Finding Text
Compliance finding (Procurement and Suspension and Debarment) and Internal Controls over Compliance (Significant Deficiency over Procurement) Department of the Interior – Fish and Wildlife Coordination Act – Assistance Listing No. 15.517; Grant period: Year Ended December 31, 2023. Criteria – In accordance with 2 CFR 200.320, participants are required to perform an appropriate form of competition in their procurement process.Condition – Management did not perform an appropriate form of competition for a service contracted during the year ending December 31, 2023. The Trust did not solicit written responses from at least three vendors and if no such responses are available, a statement explaining the procurement. Questioned costs – There are known questioned costs of $27,386 representing the reimbursements claimed for the vendor during the audit period. No likely questioned costs are noted. Context – Inspection of procurement documentation showed one out of two vendors subjected to sampling required written responses from at least three vendors, consistent with Code of Federal Regulations; 2 CFR 200.320. Price or rate quotations were not obtained timely, nor formally documented and a formal assessment was not performed. Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain sufficient documentation nor perform a formal assessment to proceed with the contracted services. Repeat finding – First year program has been audited therefore this is not a repeat finding. Recommendation – We recommend management implement a control to ensure sufficient quotes are obtained and documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response – Management has implemented and adopted a new procurement policy effective May 2023 regardless of dollar value that will maximize open and free competition and that the Trust shall not engage in procurement practices which may be considered arbitrary or restrictive. Purchases will be reviewed by the Tule Trust Finance Committee to prevent duplication and to ensure that costs are reasonable.