Finding Text
2021-007 – PROCUREMENT – PROCUREMENT QUOTATIONS
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award.” These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320 establishes thresholds for procurement methods to be utilized when acquiring property or services under a federal award including small purchases defined as follows:
Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
Condition:
Management utilizes the federally designated micro-purchase level of $10,000 and the simplified acquisition threshold of $250,000. Purchases between $10,000 and $250,000 did not have an adequate number of price or rate quotations obtained.
Questioned Costs:
$151,207
Context:
There were nine acquisitions for property and services with federal awards totaling $151,207 that were considered small purchases. Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848.
Cause:
Internal controls and procedures related to procurement were not effectively designed or performed.
SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued)
2021-007 – PROCUREMENT – PROCUREMENT QUOTATIONS (Continued)
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Effect:
Small purchases were made without obtaining an adequate number of price quotations.
Recommendation:
Management should establish proper policies and procedures which ensure transactions have the proper procurement treatment that align with federal guidelines.
Views of Responsible Officials:
Management concurs with the finding and has developed a plan to correct the finding.