Finding Text
Finding Reference Number: 2025-001 Procurement Finding. Title and CFDA Number of Federal Program: 84.351A – Assistance for Arts Education - R&D Cluster. Type of Finding: Federal Award Finding. Finding Resolution Status: In Process. Criteria: Under the Uniform Guidance (2 CFR 200.318–200.326), non Federal entities must maintain written procurement procedures that comply with federal requirements. Additionally, federal procurement rules apply regardless of whether a vendor is pre-identified by the pass through entity, unless a specific exemption applies. Statement of Condition: The Organization did not perform vendor selection procedures, competitive bidding, or document the rationale for vendor selection in accordance with its procurement policy, as the two vendors were pre-established and written into the grant agreement by the University of South Florida (USF) and the original grant agent prior to Distinctive Schools’ involvement in administering the grant. Cause: The Organization concluded that its procurement policy did not apply and therefore did not perform the required procurement procedures. Effect or Potential Effect: Failure to comply with Uniform Guidance procurement requirements may result in noncompliance with federal standards, insufficient documentation supporting vendor selection, potential questioned costs if expenditures are deemed improperly procured, and an increased risk of favoritism, unreasonable costs, or lack of competition. Questioned costs - None identified. Reportable Views of Responsible Officials: See Corrective Action Plan. Identification of Repeat Findings - This is not a repeat finding. Recommendation: Management should document a formal justification for the use of pre-selected vendors, update internal procedures to address grant-specified or inherited vendors, train program and grants personnel on Uniform Guidance procurement requirements, and maintain complete supporting documentation in the grant file, including written confirmation from the pass-through entity.