Finding Text
Questioned costs:
Impossible to quantify, given the nature of the finding.
Condition:
The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a).
Criteria:
Per 2 CFR Sec. 200.318(a), “[t]he recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327.”
Effect:
The Organization was not in compliance with the requirements of the Uniform Guidance. Lack of formal documentation of the Organization’s procurement procedures increases the likelihood that staff is unaware of the procedures and updates to them, which increases the chances that staff is noncompliant with the applicable requirements.
Cause:
The Organization inadvertently did not document its procedures in a manner consistent with the standards identified in 2 CFR 200.318(a).
Recommendation (2024-001-a):
We recommend that management draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a).
Management’s Response:
Management concurs with this finding and agrees with the auditor’s recommendations.