Finding Text
Finding No.: 2022-007
Federal Agency: U.S. Department of the Interior
AL Program: 15.875 Economic, Social, and Political Development of the Territories
Federal Award No.: Enewetak/Ujelang Local Government (EULG) Food and Agriculture
Support Program
Questioned Costs: $61,961
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 13 (or 52%) of 25 procurement transactions tested, aggregating $1,226,655 of $1,514,067 in
total transactions subject to procurement requirements, no procurement file was provided.
Item #
Encumbrance or
EULG check # Ref # Amount
QC reported at
this Finding
1 unavailable 768401 $ 5,529 $ 5,529
2 unavailable 770642 247,872 -
3 P8937001 772373 33,500 33,500
4 P8937301 774899 22,932 22,932
5 check 38047 787948 13,058 -
Condition, continued:
Item #
Encumbrance or
EULG check # Ref # Amount
QC reported at
this Finding
6 check 63794 789220 10,842 -
7 check 63798 789220 432 -
8 check 38258 789220 52,153 -
9 check 63714 790134 19,476 -
10 check 63559 790134 370 -
11 check 63872 798961 4,200 -
12 check 63941 798961 6,565 -
13 check 38350 798961 38,000 -
$ 454,929 $ 61,961
Item #s 2 and 5 through 13 are also reported as matters of noncompliance within Finding 2022-002,
including associated questioned costs.
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 $61,961.
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.