Finding Text
2024-002 – Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program: Arts in Education Federal Assistance Listing Number: 84.351A Pass-through Entity: Not applicable. Award Identification Number: S351A210115 Year: 2023 and 2024 Criteria: 2 CFR §200.320(b) requires that for purchases exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources. If a noncompetitive (single-source) procurement is used, the entity must document the justification in accordance with 2 CFR §200.320(c). Condition: During testing, we identified three vendors with transactions exceeding the micro purchase threshold. For one vendor, the Organization obtained competitive price quotations in accordance with procurement requirements. For the remaining two vendors, the Organization did not retain documentation supporting compliance procurement decisions in accordance with the Organization's. Context: Documentation for two of the three transactions did not align with the competitive procurement requirements. Given that two-thirds of the population were affected, this indicates an area where compliance practices could be strengthened. Cause: Although the Organization has a formal procurement policy outlining requirements for competitive quotes and single-source justifications in accordance with 2 CFR §200.320, these procedures were not consistently followed for the transactions tested. Effect: Failure to obtain competitive quotes or document single-source justifications increases the risk of noncompliance with federal procurement requirements and may result in unallowable costs being charged to the federal program. Questioned Costs: Known questioned costs total $167,348, representing the federal share of the transactions where procurement requirements were not met. Repeat Finding: Yes Recommendation: We recommend the Organization ensure that its procurement policy is fully implemented. Staff should be trained and held accountable for obtaining competitive price or rate quotations for all purchases exceeding the micro-purchase threshold, or for documenting appropriate single-source justifications when applicable. Views of Responsible Officials: See Corrective Action Plan.