Finding Text
Finding 2024-002: 93.591 - U.S. Department of Health and Human Services - Family Violence Prevention and Services/State Domestic Violence Coalitions Procurement and Suspension and Debarment, Non-Compliance Criteria: Per 2 CFR § 200.318(a), non-Federal entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, policies must address standards of conduct, competition, cost analysis, and methods of procurement. Condition: During the review of the Organization’s procurement procedures, it was noted that the Organization does not have an updated, written procurement policy that reflects the requirements outlined in 2 CFR § 200.318 – 200.327. The current policy on file predates the implementation of the Uniform Guidance and does not incorporate key standards such as micro-purchase thresholds, competitive bidding requirements, or conflict of interest provisions. Effect: Without an updated procurement policy that aligns with federal requirements, the Organization is at risk of noncompliant procurement practices. This could lead to unallowable costs being charged to federal awards, and potentially jeopardize future funding. Questioned Costs: None. Cause: The Organization has not reviewed or revised its procurement policy since the adoption of the Uniform Guidance, resulting in outdated internal procedures. _x000C_Recommendation: The Organization should update its procurement policy to fully align with the procurement standards outlined in 2 CFR § 200.318 through § 200.327. Staff responsible for procurement should also be trained on the updated procedures to ensure consistent and compliant practices.