Finding 1123794 (2024-001)

2024-001: Coronavirus State and Local Fiscal Recovery Fund – AL #21.027, Uniform Guidance Procurement Documentation Condition: The Organization does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: The Organization is new to this type of funding and, while having various components of policies in place, has not yet adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Questioned Cost Amount: N/A Context: Several Uniform Guidance procurement requirements were not noted in the Organization’s procurement policy. Recommendation: The Organization should revise procurement procedures to more closely align with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: EO Companies will review and write a more detailed version of procurement policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.