Finding Text
Criteria: Code of Federal Regulations, CFR 200.320, require the non-Federal entity to have and use documented
procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for the
acquisition of property or services required under a Federal award or sub-award. For “small purchases,” those where
the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition
threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined
appropriate by the non-Federal entity.
Condition: During our testing of procurement, we sampled four contracts that would qualify as “small purchases.”
The district could not provide evidence that multiple quotes had been obtained prior to selecting any of the vendors.
Cause: Due to turnover at the District, there has been a lack of oversight to ensure all appropriate documentation is
maintained to demonstrate that the District is in compliance with the Code of Federal Regulations and that purchases
are awarded after a reasonable number of quotes have been obtained.
Context: Deficiency was noted in all four contracts tested.
Effect/Questioned Cost: This resulted in roughly $122,215 awarded in contracts, without following proper
procedures.
Recommendation: We recommend that the District train and implement the required federal procurement procedures
to ensure that the District is in compliance. In addition, we recommend that the District adopt a board policy that
addresses procedures related to federal procurement.
Views of Responsible Officials: The Purchasing department will develop and maintain procurement procedures
requiring that “small purchases” of equipment or services made under a Federal award or sub-award above the micropurchase
threshold require multiple quotes and that those quotes are properly documented as evidence.