Finding Text
Finding 2024-003: Compliance finding – Procurement, Suspension, and
Debarment
U.S. Department of Treasury
State of VT Department for Children and Families
Coronavirus State & Local Fiscal Recovery Funds (ALN# 21.027)
U.S. Department of Energy
State of VT Department for Children and Families
Weatherization Assistance for Low-Income Persons (ALN# 81.042)
Condition: Required documentation within procurement files not consistently present,
such as solicitation of subcontractor bids. It is imperative that all requirements described
in the Organization’s procurement policies are clearly documented within the files as
being met or what the status of completion is in relation to the solicitation of bids.
Criteria or specific requirement: Non-federal entities other than states, including
those operating federal programs as subrecipients of states, must follow the
procurement standards set out at 2 CFR sections 200.318 through 200.327. They must
use their own documented procurement procedures, which reflect applicable state and
local laws and regulations, provided that the procurements conform to applicable federal
statutes and the procurement requirements identified in 2 CFR Part 200.
Cause: Staff attrition and lack of oversight by management.
Effect: Records to document the history of procurements not present, full and open
competition is not provided.
Questioned costs: No questioned costs were identified.
Recommendation: Although Southeastern Vermont Community Action, Inc., has a
policy in place regarding procurement, we suggest that the policy be revised to more
completely address the process and criteria as detailed in applicable federal
regulations. It is imperative that documentation of each procurement is maintained and
made easily available. The inclusion of a coversheet for each procurement can allow for
easy tracking and maintenance of records. Development of such a tool can be done in
collaboration with the audit team to ensure compliance with the federal regulations and
internal policies and procedures.