Finding Text
Finding number: 2024-003 AL Number:10.561 AL Title: Supplemental Nutrition Assistance Program Name of federal agency: U.S. Department of Agriculture Repeat Finding:Yes - 2023-002 Criteria: The Code of Federal Regulations 2 CFR 200.3 1 8(a) states, "the non-Federal entity must have and use docwnent procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward." In addition, per the Code of Federal Regulations 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations. The regulations restrict awards, subawards, and contracts with certain- parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our prior year testing, we noted the Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. In the summer of 2024, the Organization adopted a procurement policy compliant with the Code of Federal Regulations 2 CFR 200.214. The policy was formalized, announced, and implemented with the entire Organization's staff. At this time, all current contractors of federal grants were reviewed for eligibility by reviewing them against the debarred, suspended and otherwise excluded list. Management also hired a procurement officer in December 2024. Due to the changes not being in effect for approximately half of 2024, which is the year under audit, this is considered a current year finding. Cause: Procurement policies and procedures were not adopted by the Organization. Possible effect: The Organization may not have received a competitive bid for services, and may have engaged a suspended or debarred contractor. Questioned cost: None Recommendation: We recommend the Organization implement necessary internal controls to ensure a competitive bid process is performed and all vendors are reviewed for suspension and debarment, prior to entering into contracts utilizing federal awards. These internal controls should also include a conflict-of- interest clause with all vendors within contract language. Management agrees with the finding. In the summer of 2024, the Organization adopted a procurement policy compliant with the Code of Federal Regulations 2 CFR 200.214. The policy was formalized, announced, and implemented with the entire Organization's staff. At this time, all current contractors of federal grants were reviewed for eligibility by reviewing them against the debarred, suspended and otherwise excluded list. Views of responsible officials:Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined procedures around all contractors ensuring appropriate selection processes and contractual terms.