Finding Text
2023-003 – Department of the Interior Federal Program Name: Natural Resource Stewardship - Pass-Through Agency: N/A Assistance Listing Number: 15.944 Federal Award Identification Year: 2023 Award Period: 10/01/2022 – 09/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria: 2 CFR 200.319 - All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. (a) To ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids must be excluded from competing on those procurements. (b) The recipient or subrecipient must have written procedures for procurement transactions. These procedures must ensure that all solicitations: Condition: During our testing over procurement, it was noted that there is no procurement or competitive bidding policy in place or regularly followed. As Procurement is a part of the requirements this institutes a finding for not having a policy in place and actively followed. Condition: Known: $99,815 Likely: $99,815 Context: A procurement policy needs to be formally in writing and practiced regularly. Having a loose set of guidelines followed every few years does not qualify for the requirements necessary under the grant agreement. Effect: Without a procurement policy being formalized and practiced each year, this could lead to risk exposure, inflated costs, and potential conflicts of interest. Cause: No procurement policy is in place or regularly being followed. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that CIES create a procurement policy and procedures to ensure that all required procurements are performed in accordance with the guidance and criteria outlined above. Management’s Views: See separate corrective action plan.