Finding 1148418 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-07-25
Audit: 363060
Auditor: Bdo

AI Summary

  • Core Issue: PSI did not follow its own procurement procedures, leading to incomplete documentation and noncompliance with federal regulations.
  • Impacted Requirements: Violations of §200.318(a) for procurement standards and §200.320(c) for noncompetitive procurement justifications.
  • Recommended Follow-Up: Management should improve procurement tracking and clarify policies to ensure consistent compliance across all international offices.

Finding Text

2023-002 Internal Control over Compliance and Compliance with Procurement Requirements See Schedule of Findings and Questioned Costs for chart/table. Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During the audit, we tested a total of 19 procurements noting the following matters: o For one procurement sample under award 72038620CA00002, management did not provide supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the procured entity and country office. Therefore, BDO was unable to conclude that PSI complied with the required procurement regulations. o For one procurement sample under award 72061224CA00005, management renewed a lease agreement in Malawi without performing any procurement procedures to determine the renewal complied with the requirements of §200.318(a). o For one procurement sample under award 72061224CA00005, BDO noted that management utilized a single source or sole source justification for the selection rationale; however, that rationale did not conform to the requirements of limited competition per §200.320(c). Questioned Costs: There are no questioned costs. Context: This is a condition based on testing of PSI’s compliance with specified requirements. The prevalence of this finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: PSI personnel did not adhere to PSI’s documented policies and procedures for tracking procurements, for ensuring complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with PSI’s documented policies and Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management refine their procurement tracking method by clarifying established policies and procedures to create more consistency across PSI’s international office locations. Views of Responsible Officials: PSI management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 571964 2024-003
    Significant Deficiency Repeat
  • 571965 2024-004
    Significant Deficiency Repeat
  • 571966 2024-005
    Significant Deficiency Repeat
  • 571967 2024-004
    Significant Deficiency Repeat
  • 571968 2024-003
    Significant Deficiency Repeat
  • 571969 2024-002
    Significant Deficiency
  • 571970 2024-001
    Significant Deficiency Repeat
  • 571971 2024-004
    Significant Deficiency Repeat
  • 571972 2024-004
    Significant Deficiency Repeat
  • 571973 2024-004
    Significant Deficiency Repeat
  • 571974 2024-005
    Significant Deficiency Repeat
  • 571975 2024-004
    Significant Deficiency Repeat
  • 571976 2024-002
    Significant Deficiency
  • 571977 2024-004
    Significant Deficiency Repeat
  • 1148406 2024-003
    Significant Deficiency Repeat
  • 1148407 2024-004
    Significant Deficiency Repeat
  • 1148408 2024-005
    Significant Deficiency Repeat
  • 1148409 2024-004
    Significant Deficiency Repeat
  • 1148410 2024-003
    Significant Deficiency Repeat
  • 1148411 2024-002
    Significant Deficiency
  • 1148412 2024-001
    Significant Deficiency Repeat
  • 1148413 2024-004
    Significant Deficiency Repeat
  • 1148414 2024-004
    Significant Deficiency Repeat
  • 1148415 2024-004
    Significant Deficiency Repeat
  • 1148416 2024-005
    Significant Deficiency Repeat
  • 1148417 2024-004
    Significant Deficiency Repeat
  • 1148419 2024-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $15.54M
98.U00 Usaid Cost Reimbursable Contracts and Other Awards $699,472
98.001 Covid 19 - Usaid Foreign Assistance for Programs Overseas $344,479
98.U00 Covid 19 - Usaid Cost Reimbursable Contracts and Other Awards $186,371
12.420 Military Medical Research and Development $73,012
12.350 Department of Defense Hiv/aids Prevention Program $35,605
93.067 Global Aids $-1,305