Finding 2025-002: Procurement, Suspension and Debarment Federal Agency: U.S. Agency for International Development (USAID) Federal Program: Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Pass-through Entity (if applicable): Not applicable Award Identification Number and Year: All Criteria or Specific Requirement: 2 CFR 200.318 through 200.327; 2 CFR 200.303 Recipients and subrecipients must maintain and use documented procurement procedures consistent with applicable laws and the Federal procurement standards. Procurement transactions must be conducted using an appropriate method, with records sufficient to support the procurement history and required determinations. The standards also address competition, conflicts of interest, contractor oversight, cost or price analysis when applicable, required contract provisions, and suspension and debarment requirements. Condition: For several procurement transactions sampled, Internews Network was unable to provide some or all documentation necessary to support compliance. Missing items included procurement method determination, solicitation or quotations, bid/proposal evaluation, sole-source justification, price reasonableness or cost/price analysis. Accordingly, we were unable to determine whether the transactions were procured in accordance with Internews Network’s policies, 2 CFR 200.318 through 200.327, and applicable award terms. Cause: Management indicated that significant staffing reductions followed the termination of Federal awards and funding. Procurement and grants administration duties were dispersed or discontinued without a complete transition of electronic and paper records. Management did not have an enforced, centralized procurement file standard or a closeout control designed to confirm that each procurement file was complete before responsible staff separated. Effect or Potential Effect: The missing documentation prevented verification that procurement transactions were conducted with the required competition, approvals, price considerations, exclusion checks, and contract terms. This increases the risk of unsupported vendor selection, unreasonable costs, transactions with excluded parties, omitted Federal clauses, and costs that may be challenged by a Federal agency or pass-through entity. Questioned Costs: Undetermined Context: Internews Network used Federal award funds to acquire goods and services under during the audit period. Compliance with Federal procurement requirements is ordinarily demonstrated through a contemporaneous procurement file documenting the applicable method, competition or authorized noncompetitive justification, vendor selection, price or cost considerations, approvals, exclusion checks, contract terms, and oversight. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: Implement a standardized procurement checklist scaled to method and threshold. Retain the funding source, threshold and method determination, competition or approved noncompetitive justification, vendor responses, evaluation, price support, conflicts documentation, exclusion verification, approvals, contract provisions, invoices, and oversight evidence. Require independent completeness reviews before award and final payment, centralize records, and use a staffing-reduction or award-termination protocol to transfer ownership, preserve access, and certify file completeness.