Finding Text
Criteria: The acquisition of property or services which is higher than the micro-purchase threshold ($10,000 at the time of the grant in question) but does not exceed the simplified acquisition threshold ($250,000 established in the FAR) must follow small purchase procedures. Small purchase procedures include price or rate quotations obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, the non-Federal entity may select noncompetitive procurement as their procurement method but must meet one of the five mentioned circumstances in 2 CFR 200.320(c). Lastly, general procurement standards must be followed. Questioned Costs: None. Repeat finding: The same finding was reported during the program specific audit as of and for the year ended December 31, 2022 as 2022-001. Recommendation: We recommend that the Organization adopt a procurement procedure in compliance with 2 CFR and ensure they have a full understanding of the required procurement policy. Views of Responsible Officials: A procurement procedure has since been adopted and approved by the Board. The Executive Director will ensure that all future purchases comply with 2 CFR. Condition: During our audit, certain grant expenditures with subcontractors, exceeding $10,000, were tested for which the Organization did not obtain quotes for. Cause: The Organization did not obtain quotes from subcontractors that were included in a contractor’s original bid. The Organization ultimately paid the subcontractors directly. Effect: The Organization did not adequately comply with 2 CFR 200.320. Non-compliance could lead to additional compliance concerns and questioned costs.