Finding Text
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); U.S. Department of Health and Human Services; Assistance Listing Number 93.323; Award Number E20242798-00. Criteria. When conducting procurement transactions under a Federal award, the University must follow the same policies and procedures it uses for procurements with non-Federal funds which states that sealed bids must be obtained for items in excess of $5,000 or clearly document reasons as to why bids could not be obtained. Condition. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. Cause. The University lacks a review process for purchases in excess of $5,000 to ensure sole-sourcing arrangements are documented. Effect. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.