Finding Text
Reportable Finding Considered a Significant Deficiency and Noncompliance Finding – Procurement Agency: U.S. Department of State, Bureau of Population, Refugees, and Migration (PRM) Program: U.S. Refugee Admissions Program ALN# 19.510 Grant Number: SPRMCO25CA0026, SPRMCO25CA0028, and SPRMCO24CA0337 Program Year: 2025 Criteria: The auditee must maintain and follow documented procurement policies and procedures that comply with Uniform Guidance procurement requirements. Noncompetitive procurement (sole source) may only be used when one of the circumstances in 2 CFR 200.320(c) applies and must be adequately documented. Condition: The Organization did not have a formal written procurement policy during the audit period. In addition, for the procurement selections tested that were procured through sole source methods, management did not maintain documentation demonstrating that the procurements met the criteria for noncompetitive procurement under 2 CFR 200.320(c). Cause: Management had not established formal procurement policies and procedures and did not implement controls to ensure sole source procurements were appropriately justified and documented in accordance with Uniform Guidance requirements. Effect: Without documented procurement policies and support for sole source procurements, the Organization cannot demonstrate compliance with federal procurement requirements. This increases the risk that procurements may not be conducted in a manner that promotes full and open competition. Questioned costs: None Perspective: Statistical sampling was not used; however, a nonstatistical sampling approach was applied in accordance with AICPA guidance. This appears to be a systemic issue, as the Organization lacked a formal procurement policy during the audit period. Additionally, sole source procurements tested did not include documentation demonstrating that the conditions permitting noncompetitive procurement were met. Repeat finding: This is not a repeat finding. Recommendation: Management should develop and formally adopt written procurement policies and procedures that comply with Uniform Guidance requirements. The policies should include requirements for procurement methods, documentation standards, conflict of interest considerations, and approval procedures. In addition, management should ensure that all sole source procurements are supported by documentation demonstrating that the procurement met one of the allowable circumstances for noncompetitive procurement under 2 CFR 200.320(c) and retain such documentation in the procurement file. Management’s response (unaudited): See Corrective Action Plan