Core Issue: The Organization lacks a formal procurement policy, which is required for compliance with Federal standards.
Impacted Requirements: Non-Federal entities must adhere to procurement standards outlined in 2 CFR sections 200.318 through 200.326.
Recommended Follow-up: Management should create and implement a formal written procurement policy to ensure compliance and mitigate future funding risks.
Finding Text
Criteria: 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 200.326. 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. Condition: The Organization did not provide a procurement policy. Cause: The Organization does not have internal controls in place surrounding procurement policies and procedures. Effect: The lack of internal controls surrounding the procurement policies and procedures could lead to potential funding issues in the future. Questioned Costs: None. Recommendation: We recommend that management establish a formal written procurement policy. Organization’s Response: Management agrees with this finding.
Corrective Action Plan
Management Response: The Organization will establish a procurement policy in 2025. Anticipated Completion Date: 12/31/2025 Responsible Party: Board of Directors
Categories
Questioned CostsProcurement, Suspension & DebarmentSubrecipient MonitoringMatching / Level of Effort / EarmarkingInternal Control / Segregation of Duties