Finding Text
Finding 2023-003: Procurement (Significant Deficiency)
Federal Programs: All programs
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code.
Condition: The Association did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable in all instances during our audit. In addition, there was no documented review process by the Association to determine if vendors were suspended or disbarred.
Cause: The Association's internal policies and procedures governing procurement were not consistently applied or updated.
Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that the Association will not perform proper evaluation of each element of cost to determine reasonableness and apply appropriate procedures to evaluate procurement standards were followed.
Questioned Costs: None noted.
Consequence of the Audit Finding: Our procedures consisted of tests of internal control and compliance over a sample of procurements subjected to the Association's procurement policies. We consider our sample to be representative of the population. The condition appeared to be systematic in nature.
Identification as a Repeat Finding, if Applicable: 2022-005
Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation.
Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
Anticipated Completion Date: November 2024
Responsible Official: Michael Brosnan, Chief Financial Officer