Finding 1220129 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-29
Audit: 405305
Organization: Civil Air Patrol (AL)

AI Summary

  • Core Issue: Incomplete documentation for five purchase orders during the fourth quarter, violating federal and CAP procurement requirements.
  • Impacted Requirements: Failure to maintain adequate records as per 2 CFR 200.318(i) and CAP regulation NHQ OI GC 24-02 for procurements over $25,000.
  • Recommended Follow-Up: Ensure all procurement documentation is filed by vendor and complete the Procurement File Review Checklist for each transaction to enhance compliance.

Finding Text

Information on the federal program: United States Airforce, Assistance listing # 12.840 Civil Air Patrol Program Criteria: 2 CFR 200.318(i) states, "The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price." CAP regulation NHQ OI GC 24-02 section 18.3, states, "CAP/GCC will conduct procurement file reviews for all procurements costing $25,000 or more. The CAPF GCC-06, Procurement File Review Checklist, will be used to document the review." The Procurement File Review Checklist requires General Counsel review of all procurements over $100,000. Condition: Documentation of the procurement procedures of five purchase orders examined in the fourth quarter of the fiscal year were not complete. Cause: Controls and related responsibilities were not updated to address staffing changes in the contract and legal departments. Effect: Several components of the required documentation of five procurements examined from the fourth quarter of the fiscal year were not available upon request. Repeat Finding: No Questioned Costs: None reported. Recommendation: Documentation for each procurement should be maintained in a file by vendor. CAP's procurement file checklist should be completed retrospectively and included in the file for each procurement to ensure the completeness of the documentation. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.

Corrective Action Plan

We concur with the finding and are implementing procedures to address all issues. Civil Air Patrol (CAP) experienced turnover in key positions within the General Counsel and Contracting offices, which resulted in a lapse in the consistent execution of procurement file review controls. As a result, certain required procurement reviews were not completed in accordance with CAP policy. CAP has since filled the vacant positions and initiated a comprehensive review of procurement files. This review includes the completion of the CAPF GCC-06 Procurement File Review Checklist, as required, and the retroactive reconciliation of procurement documentation to the extent practicable. In addition, CAP is strengthening internal controls by enhancing monitoring procedures to ensure procurement file completeness prior to closeout and providing targeted training to procurement and program staff on applicable federal and internal documentation requirements. CAP expects to complete the retrospective file review and fully implement these enhanced controls by 30 September 2026.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1220130 2025-004
    Material Weakness Repeat
  • 1220131 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
12.840 CIVIL AIR PATROL PROGRAM $80.38M