Finding Text
2024-001 – Coronavirus Capital Projects Fund - Assistance Listing No. 21.029; Grant Period - For the year ended December 31, 2024 Condition: The Organization did not comply with the approved procurement policy for expenses that were claimed under the federal program. Criteria: The Organization’s procurement policy states that the Organization will follow 2 CFR 200.320 for federal procurement methods. Cause: The Organization did not have the necessary procedures in place to comply with the federal procurement methods for 2 of 8 invoices selected for testing. Effect of Condition: The Organization was unable to provide documentation that the federal procurement methods were followed for 2 of 8 invoices selected for testing. Questioned Cost: None. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Organization's should adopt procedures to ensure federal procurement methods are followed for all purchases under a federal contract. Views of Responsible Officials and Planned Corrective Actions: At the time of the transactions in question, the Organization operated under the understanding that multiple bids were required only for costs exceeding $50,000. The Organization was then provided updated guidance from our audit firm indicating that the correct threshold was $10,000. This shift demonstrates the complexity of interpreting and applying procurement rules. Since the beginning of the grant, the Organization has actively researched and sought clarification on the applicable purchasing and contracting requirements. Unfortunately, different sources provided conflicting thresholds and requirements. Based on the information available at the time, the Organization made a deliberate and well-reasoned decision not to seek multiple bids for certain expenditures. The grant funding source received full documentation for these costs, did not raise concerns, and reimbursed the expenses without issue. The Organization acted in good faith and in alignment with the guidance it had at the time of these purchases. To address this finding the Organization has implemented a revised procurement policy requiring multiple bids or sole source rationale for any purchases exceeding $10,000. Staff have been made aware of this threshold, and procedures are in place to ensure compliance moving forward.