Finding Text
Criteria
Part 2, CFR 200, 200.318 states “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.”
Condition
While performing tests of NBCC’s internal controls over compliance, while the Organization did have a procurement policy, the policy was not being followed. This included not obtaining and documenting competitive bids or quotes, as well as not verifying whether vendors are suspended or debarred entities.
Cause
NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines.
Repeat Finding
No.
Effect
Noncompliance may impact future funding from Federal awards. Additionally, lack of compliance may lead to contracting with ineligible vendors.
Recommendation
We recommend NBCC implement proper internal control procedures including implementing and following a procurement policy in line with the Uniform Guidance.