Finding Text
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.