2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal 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: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. Corrective Action: Effective June 15, 2022, the procurement policy will be adhered to and purchases will be adequately documented. Responsible Persons: Stephanie Vullo, Chief Compliance Officer, 718-780-0605, stephanie.vullo@brooklaw.edu; Herberth Melendez, Associate General Counsel, 718-780-7952, herberth.melendez@brooklaw.edu