Finding 1157391 (2024-001)

MATERIAL WEAKNESS Finding 2024-001 Procurement Policy Program Affected: ALN 45.164, Promotion of the Humanities Public Programs Compliance Requirement: Procurement, Suspension, and Debarment Criteria: Uniform Guidance requires non-Federal entities to establish and follow procurement policies that: • Include procedures to verify vendor eligibility through SAM.gov (2 CFR §200.214). • Define procurement methods and thresholds. • Incorporate a domestic preference for procurements (2 CFR §200.322). • Establish documented procedures for handling procurement disputes, protests, and source evaluations. Condition: The Center’s procurement policy has not been formally updated to incorporate the current Federal requirements under Uniform Guidance. Cause: Management has not yet revised the policy to reflect recent regulatory updates. Effect: In the absence of a fully compliant procurement policy, the Center is at heightened risk of: • Contracting with ineligible or debarred vendors. • Failing to demonstrate compliance with Federal procurement standards. • Maintaining insufficient documentation to support procurement decisions. Questioned Costs: None identified. Repeat Finding: No. Recommendation: We recommend that management amend and formally update the procurement policy to ensure compliance with Uniform Guidance by addressing: • Vendor verification and debarment testing. • Procurement methods and procedures. • Domestic preference requirements. • Procedures for resolving procurement issues, protests, and evaluations. Management Response: The Center will work with the Board of Directors to establish and implement a formal procurement policy by December 15, 2025. The policy will incorporate procedures for verifying vendor eligibility through the SAM.gov exclusions list, set clear requirements for procurement at different thresholds (including obtaining multiple quotes when necessary), and align with Federal guidelines by prioritizing U.S.-made products when feasible. It will also address vendor selection reviews, dispute resolution, and documentation standards to ensure fairness, transparency, and audit readiness. Management will monitor compliance and include provisions for version control and periodic review of the policy.