Finding 1096320 (2023-001)

Criteria: The Uniform Guidance requires that District 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 #10.760. 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 non compliance related to this requirement. Cause: Management has outsourced the procurement process to an engineering firm. While the firm has knowledge and experience regarding Uniform Guidance procurement, they do not develop policies for their clients. 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.