Finding Text
#2024-006 – Major Federal Award Finding – Procurement and Suspension and Debarment Nature of Finding: Administrative Requirements – Procurement Policy/Documentation Compliance Finding and Material Weakness in Internal Control over Compliance Criteria/Condition: The Organization did not have a formal procurement policy as required by 2 CFR 200.320 until June 2024. Six out of thirteen vendor contracts were in place before the policy was formalized. Documentation supporting various procurement decisions was not retained. Cause/Context: Documentation was lacking for the following contracts as required by the procurement standards of 2 CFR 200.320: • Evidence of price quotations was not retained for one contract tested above the micro-purchase threshold (but below the simplified acquisition threshold). Such evidence would be required under the Organization’s current procurement policy (in place June 2024). • Evidence of procurement rationale was not retained for three contractor selections above the micro-purchase threshold (but below the simplified acquisition threshold). Management provided memorandums documenting vendor selection process and rationale during the audit. • Evidence of public solicitation for bid/proposal was not retained for one contract that was above the simplified acquisition threshold (currently $250,000) in accordance with 2 CFR 200.320(b). Management provided a memorandum documenting the assessment and solicitation of various providers, the selection process and rationale during the audit. Effect: Contracts executed prior to the enacted procurement policy could have been created without ensuring full and open competition in compliance with 2 CFR 200.320. Recommendation: We recommend that TalentFirst, Inc. follow procurement standards that comply with the requirements of Uniform Guidance and 2 CFR 200.320, including the retention of documentation to support purchasing decisions. Views of Responsible Officials and Planned Corrective Actions: All procurement following the adoption of the procurement policy have been done in alignment with the policy. We also introduced procurement “kickoff meetings’ for new grants to review each budget line, determine the correct procurement method and plan documentation.