Finding Text
Finding 2024-004 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement Identification of the federal program Agencies Award Numbers ALN 15.022 Tribal Self Governance ` Department of Interior GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Criteria The Uniform Guidance in 2 CFR Section 200.320(b), Procurement Methods – Small Purchase, is required if the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Unless specified by the Federal agency, the recipient or subrecipient may exercise judgment in determining what number is adequate. The recipient or subrecipient is responsible for determining an appropriate small purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures, which may be lower than, but must not exceed, the threshold established in the Federal Acquisition Regulation. Condition The Association is not consistently following their own internal control policy for purchases that meet their small purchase threshold for procurement to obtain price or rate quotations from an adequate number of qualified sources. Cause AVCP is subject to high turnover in its purchasing department. Due to the frequency of new personal onboarding, the small purchase policy was missed was certain contracts. Effect or possible effect The Association not adhering to its established procedures, can lead to noncompliance, questioned costs, repayment obligations, or loss of funding. Questioned Costs None Identified. Context 2 out of 5 vendors selected for testing were not procured for in accordance with AVCP’s policy. Identification as a Repeat Finding None. Recommendation We recommend AVCP implement additional internal controls to ensure AVCP’s internal procurement policies are being followed. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. Thorough training in AVCP’s procurement policies and procedures will be provided to departmental staff. AVCP will also hold an overall training of AVCP’s key and senior personnel by an outside expert in government procurement rules and regulations.