Finding Text
Finding 2023-004: Procurement (Significant Deficiency)
Information on the Federal Program: ALN 19.663 Global Telecommunications and Emerging
Technology Training
Criteria: 2 CFR 200.318 states that non-Federal entities must have and use documented procurement
procedures consistent with the requirements for procurement regulations included in paragraphs 318
through 327.
Condition: We noted procurement procedures are outsourced to a third party, but management is
heavily involved in the ultimate decision. However, the procurement policy is not formalized and
procurement actions are not documented and maintained in USTTI's vendor files.
Cause: USTTI did not have a documented formal procurement policy in accordance with the Uniform
Guidance.
Effect: A lack of a formal procurement policy is insufficient to meet the requirements of the Uniform
Guidance as noted in the Criteria section above.
Questioned Costs: None.
Context: Because USTTI does not have a formal procurement policy, it is not in compliance with the
Uniform Guidance.Context (continued): Our audit work in this area consisted of a test of internal controls over a random
sample of expenditures, as well as substantive tests of details over transactions above a defined
threshold from select expense accounts that were charged to the Federal program. We consider our
samples to be representative of the respective populations, and thus, are statistically valid samples.
Due to the timing of the audit for the year ended December 31, 2022, USTTI was not able to formalize
a policy for the year ended December 31, 2023. We noted that USTTI has formalized a procurement
policy during the year ended December 31, 2024.
Identification as a Repeat Finding: Yes. See Finding 2022-03.
Recommendation: We recommend USTTI formalize a procurement policy which is in compliance with
the Uniform Guidance. We also recommend that USTTI management ensure the procurement policy is
distributed and communicated in a formal manner to its employees, and that management properly
enforce compliance with the policy. All procurement actions should be clearly documented in writing
and maintained in the vendor or contractor files.