Finding Text
Legal Services Corporation
FFAL #09‐742018 Legal Services Corporation – Basic Field – Basic
FFAL #09‐742018 Legal Services Corporation – Basic Field – Native American
Procurement
Material Weakness in Internal Control over Compliance
Criteria: 45 CFR 1631 requires that a non‐Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law.
Condition: Our testing detected two instances in which the transaction exceeded the Organization’s small purchase threshold of $4,000, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed.
Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing the Organization’s considerations over the procurement process.
Effect: Without completing a written evaluation detailing the history of procurement, demonstrating the program complies with laws, regulations, and other compliance requirements is difficult.
Questioned Costs: None reported based on assessment of comparative pricing readily available.
Context/Sampling: A nonstatistical sample of 60 disbursements out of more than 250 disbursements were selected for testing. Out of the 60 disbursements, two items exceeded the Organization’s small purchase threshold.
Repeat Finding from Prior Year: Yes. 2023‐004 reported a similar finding over procurement.
Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained.
Views of Responsible Officials: Management is in agreement.