Finding Text
Criteria: Per 2 CFR 200.318(a), entities must use their own documented procurement procedures, which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in the Uniform Guidance. Condition: During our audit, we noted that the entity does not have a documented procurement policy. As a result, there is no formal guidance to ensure that procurement transactions are conducted in accordance with applicable federal regulations, including requirements related to full and open competition, appropriate procurement methods based on dollar thresholds, and verification of suspension and debarment. Cause: While Social Enterprise Properties’ management is aware of the procurement policies and procedures in the Uniform Guidance, management had not documented formal policies and procedures. Effect or potential effect: Without a documented procurement policy, there is an increased risk of noncompliance with federal procurement standards, including inappropriate procurement methods, lack of required competition, or failure to check for suspension or debarment. This could lead to questioned costs or disallowed expenditures under federal awards. Recommendation: We recommend that Social Enterprise Properties’ develop and adopt a written procurement policy that is consistent with the requirements of 2 CFR 200 Part D. The policy should outline thresholds, procurement methods, and procedures for verifying suspension and debarment. Questioned costs: None identified. Views of responsible officials: Management has developed and put in place a written procurement policy effective May 1, 2025.