Finding Text
Criteria An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in 2 CFR § 200.317 through 200.327. For purchases below the simplified acquisition threshold (SAT) but above the micro-purchase threshold, 2 CFR § 200.320(a) requires the non-Federal entity to obtain price or rate quotations from an adequate number of qualified sources. Condition The Program used federal grant funds to pay a single contractor $222,080 in the aggregate for installation services performed at individual homes. As a small purchase under 2 CFR 200.320(a), the procurement required the Program to obtain price or rate quotations from an adequate number of qualified sources. The Program did not solicit or document quotations from more than one source prior to engaging the contractor. Cause The Program was not fully educated on procurement policies when it came to grant funds, so they were not aware that bids or price comparisons were necessary for the purchases. Effect Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed or subject the entity to possible claims. Recommendation We recommend management adhere to the Federal, State, and local regulations for all procurements using Federally sourced funds by ensuring policies and procedures are documented and followed in accordance with Uniform Guidance requirements. Management's Response Management agrees with our recommendation and finding and will work to adhere to all applicable procurement policies. Questioned Costs None. Although the Program did not follow the required competitive procurement procedures for this contractor, the costs incurred were reasonable and allowable under the terms of the Federal award and applicable cost principles. The deficiency relates to noncompliance with procurement standards, not to the propriety of the costs themselves; accordingly, no costs are questioned.