Finding Text
Criteria: Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: GLIDE did not maintain formal evidence of review and approval of contracts subject to procurement standards. In addition, GLIDE did not have a procurement policy in place that conformed to the federal procurement requirements. Questioned Costs: There were no questioned costs identified.Recommendation: Update the written procurement policy to align with applicable federal requirements, train responsible personnel, and require a complete procurement file for each covered purchase, including the procurement method, quotes or bids as applicable, evaluation and selection rationale, conflict-of-interest considerations, and evidence of approval. Repeat finding: This is not a repeat finding. Context: We obtained a population of contracts exceeding $10,000 and selected two of the four contracts for testing, totaling $97,430. GLIDE provided supporting documentation demonstrating that multiple bids were obtained and evaluated for the contracts selected. However, management was unable to provide documentation evidencing the formal review and approval of contracts subject to procurement standards. Cause: Procurement controls were not effectively designed and implemented. Management did not ensure that procurement procedures were aligned with federal requirements or that supporting documentation to evidence review and approval was retained in the procurement file. Effect: Without documentation of approval, GLIDE cannot demonstrate controls were operating effectively to ensure compliance with federal procurement standards, including full and open competition and required procurement history documentation.