Finding Text
Finding 2024-003: Procurement
Information on the Federal Programs: ALN 14.235
Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR) Part 200,
paragraph 318 “General procurement standards” states that the non-Federal entity must use its own
documented procurement procedures which reflect applicable State, local, and tribal laws and
regulations, provided that the procurements conform to applicable Federal law and the standards.
Furthermore, paragraph 319 “Competition” states that all procurement transactions must be
conducted in a manner providing full and open competition consistent with these standards.
Condition: NEW has a procurement policy, which requires full and open competition for purchases
of goods and services in excess of a certain threshold. We noted an instance where procurement
procedures were not performed on certain purchases in excess of the threshold during the fiscal
year.
Cause: NEW failed to adhere to its procurement policy, resulting in noncompliance with Federal
standards.
Effect or Potential Effect: NEW may have disallowed costs for not properly procuring goods or
services.
Questioned Costs: $36,061
Context: NEW is at risk of entering into contracts for goods or services under Federal awards that
were not adequately procured based on the regulations in the Uniform Guidance and the awarding
agency or pass-through entity could disallow the costs paid for the goods or services.Identification as a Repeat Finding, if Applicable: Not applicable
Recommendation: We recommend that NEW ensure its policy is distributed and communicated in
a formal manner to its employees, and that management properly enforce compliance with its policy.
All procurement actions should be clearly documented in writing and maintained in the vendor or
contractor files.