Finding Text
Finding No.: 2022-006
Federal Agency: U.S. Department of the Interior
AL Program: 15.875 Economic, Social, and Political Development of the Territories
Federal Award No.: Compact Sector Grants
Questioned Costs: $44,942
Area: Procurement and Suspension and Debarment
Criteria:
Article VI, Section 1(j)(1) of the Fiscal Procedures Agreement (FPA) states that RepMar may use
its own procedures for procurement, whether done by the government or its Sub-Grantees, provided
that they meet the standards identified in the FPA.
(a) Section 124 - unless otherwise authorized by law, all Government contracts shall be awarded by
competitive sealed bidding.
(b) Section 127 - procurement of goods and services not exceeding $25,000 may be made in
purchase procedures are those relatively simple and informal methods for securing services,
Banking and Postal Services has previously declared that if small purchase procedures are used,
price or rate quotations shall be obtained from three qualified sources.
(c) Section 128 - a contract may be awarded for a supply, service, or construction item without
competition when it is determined in writing that there is only one source for the required supply,
service, or construction item.
Condition:
For 4 (or 7%) of 60 procurement transactions tested, aggregating $2,006,444 of $10,668,605 in total
transactions subject to procurement requirements, no procurement file was provided.
Fund # Encumbrance # Ref # Amount
410100 A26328 795172 $ 3,826
410102 P86331 764579 8,614
510110 P87912 764652 23,301
510110 P87510 764653 9,201
$ 44,942
Cause:
RepMar did not enforce internal control policies and procedures over documentation of the
procurement process to satisfy compliance with applicable procurement requirements.
Effect:
RepMar is in noncompliance with applicable procurement requirements. The reportable questioned
cost is $44,942.
Identification as a Repeat Finding:
Finding No. 2021-005
Recommendation:
Responsible personnel should require that documentation be adequate to comply with applicable
procurement requirements. Specifically, documentation should indicate the history of procurement,
including the rationale for contractor or vendor selection.
Views of Responsible Officials:
We agree with the finding and provide details in our Corrective Action Plan.