Finding 1236508 (2025-005)

Finding 2025-005 Noncompliance over Procurement Significant deficiency/ Noncompliance Criteria: The Organization should establish and maintain written procurement procedures to ensure that purchases and contracts supported by federal awards are conducted in accordance with applicable federal procurement standards, including required full and open competition and required methods of procurement. The Uniform Guidance procurement standards are contained in 2 CFR Part 200, Subpart D, §§ 200.317–200.327 generally, including 2 CFR § 200.319 (Competition) and 2 CFR § 200.320 (Methods of procurement to be followed). Condition and Context: During our testing of the Organization’s procurement compliance requirements, we noted two contracts that should have been procured using competitive bidding; however, the Organization did not complete competitive bidding for these contracts. Cause: The Organization did not have sufficient procedures in place to ensure that procurement actions were consistently evaluated for required competitive procurement methods and that compliance with applicable procurement requirements was documented and reviewed prior to contract award. Effect: Failure to follow applicable competitive procurement requirements may result in noncompliance with federal procurement standards and may increase the risk that contracts are awarded without maximizing open and free competition. In addition, inadequate procurement documentation reduces management’s ability to demonstrate that procurement actions are conducted in accordance with applicable requirements. Questioned Costs: None noted. Repeat Finding: This is not a repeat finding. Recommendation: Management should establish or strengthen procurement policies and procedures to ensure that contracts subject to competitive procurement requirements are competitively bid and that procurement actions are appropriately documented. Such procedures may include developing standardized procurement checklists, requiring supervisory review of procurement method selection and documentation prior to contract award, and providing periodic training to staff responsible for procurement. Management Response: Management concurs with this finding. See Corrective Action Plan.