Finding 1096288 (2024-001)

Criteria: The Uniform Guidance requires that Organization have written procurement policies in place that comply with 2 CFR Sections 200.318 – 300.327 when procurement is applicable to a federal program. According to the compliance requirements matrix, procurement is applicable to ALN #21.027. Condition: While testing the procurement compliance requirement, we found that management had not adopted the required policies contained in 2 CFR Sections 200.318 – 300.327. We did not, however, find any evidence of material noncompliance related to this requirement. Cause: Management does not regularly expend federal dollars above the threshold requiring a Single Audit under the Uniform Guidance. As such, policies related to procurement were not adopted. Effect: Internal controls surrounding Uniform Guidance are incomplete. Recommendation: Management should review 2 CFR Sections 200.138 – 300.327 and develop written policies that comply with the compliance requirements. Questioned Costs: None Management’s Response: Management will review their current procurement policies and make any necessary changes to update the policies to be compliant with 2 CFR Sections 200.138 – 300.327.