Finding Text
Criteria: 2 CFR sections §200.212 and §200.318(h); 48 CFR section §52.209-6 outlines that the non-Federal entity must maintain a procurement policy and verify that agencies in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Center does not have a procurement policy in place nor does it retain the documentation of verification of vendors not suspended or debarred prior to entering into a contract with vendors. Cause: The Center does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written financial purchasing policy, if the Center does not maintain sufficient documentation of procurement evaluations and decisions, the Center's procurement practices will not comply with the Uniform Guidance. Questioned Costs: None Recommendation: The Center should develop a procurement policy in accordance with Uniform Guidance requirements and retain formal documentation with regard to its procurement decisions. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.