Impacted Requirements: Noncompetitive procurements were not justified or documented as required by CFR 200.320(c).
Recommended Follow-Up: Ensure compliance by documenting all noncompetitive procurements as per the established procurement policy and federal regulations.
Finding Text
Information on the Federal Programs: All Programs
Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327.
Condition: The Organization maintains a procurement policy however its practices do not consistenly evidence a documented process. During our audit we noted several instances where consultants were engaged without any documentation of procurement process or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c).
Cause: The Organization did not follow its policies related to noncompetitive procurements.
Context: The Organization may be 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.
Effect: The Organization may have disallowed costs for not properly procuring goods or services.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not applicable.
Recommendation: We recommend the Organization follow its procurement policy to ensure compliance with CFR 200. Any procurements related to noncompetitive solicitations should be documented according to the provisions in CFR 200.320(c).
Corrective Action Plan
Management Views and Corrective Action Plan: Management agrees with the finding and recommendation.
Name and Title of Responsible Official: Michael Stock, Board Chairman
Planned Completion Date: Immediately.