Finding Text
Finding 2024-003: Procurement Policy Federal Agency: Department of Commerce Pass-Through Entities: North Pacific Research Board, Alaska Department of Fish and Game Program Name: Research and Development Cluster Assistance Listing Number: 11.437, 11.469, 11.472 Award Year: January 1, 2024-December 31, 2024 Program Expenditures: $2,462,741 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D, Procurement Standards (200.317-200.327), entities receiving federal awards are required to have a procurement policy that meets specific compliance criteria. Condition and context: In 2024, the Foundation operated without a formal procurement policy, resulting in significant deficiencies in internal control. The Foundation operated informally with procedures in place to ensure compliance, including internal controls over procurement and suspension and debarment, but lacked the written policy until 2025 when it was implemented by the Board formally. Cause: The Foundation lacked sufficient written policy to comply with federal funding requirements. Effect: The Foundation did not have proper policies in place, as required by federal agencies. Questioned Costs: $0 Repeat Finding: No Recommendation: We recommend Bering Sea Fisheries Research Foundation formally implement a procurement policy. View of Responsible Officials and planned corrective actions: Management agrees with the finding. Please see corrective action plan attached.