Finding Text
Finding 2024-002: Procurement – Material Weakness
Federal Agency: Institute of Museum and Library Services
Federal Program Titles: Museums for America
Federal Assistance Listing Number: 45.301
Compliance Requirement: Procurement
Criteria
Under Uniform Guidance, non-federal entities must justify the use of sole source procurement through appropriate documentation. This includes providing a clear rationale for selecting a sole source vendor, conducting and documenting market research to confirm that the product or service is available only from a single source, and obtaining the necessary approvals as required by the recipient's internal procurement policies.
Condition
We noted several instances of procurement purchases deemed to be sole source that did not adhere to the established procurement requirements. Specifically, required contemporaneous written internal support for sole source awards were either incomplete or not retained.
Context
The Museum was unable to provide sufficient written documentation to support the justification for sole source vendor selections.
Cause
The Museum's internal controls to ensure that procurement procedures, particularly those related to sole source procurements, were not effectively implemented.
Effect
The Museum may inadvertently engage vendors through procurement processes without written documentation of sole sourcing. This could lead to reduced accountability and potential disallowance of federal expenditures.
Questioned costs
None.
Identification of a repeat finding
This is not a repeat finding.
Recommendation
The Museum should review and enhance its procurement procedures and provide periodic staff training to ensure compliance with the Uniform Guidance. This includes clearly defining and enforcing documentation requirements for all procurement types, particularly sole source procurements. Additionally, implementing a standardized procurement checklist and approval workflow will help ensure proper justification, competitive solicitation when required, and appropriate documentation retention. Periodic reviews of procurement activities should also be conducted to verify ongoing compliance and to identify and address any procedural gaps.
Views of responsible officials
The National Building Museum's existing written procurement policy strives to adhere to all applicable federal regulations and guidelines. In excuting this grant, the Museum selected sole source contracts whose expertise aligned specifically with the project's objectives. The Museum provided regualr updates to the granting agency, the institute of Museum and Library Services (IMLS), which was informed of and verbally agreed to the Museum's intent and justification for sole sourcing. The Museum was awaiting a written acknologement when the agency was disbanded on March 31, 2025.