Finding Text
Federal Agency: U.S. Department of Agriculture Federal Program Title: Foreign Market Development Cluster Assistance Listing Number: 10.601, 10.618 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: Federal regulations require recipients of federal funds to document the history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Federal regulations also specify certain procurement methods that recipients must use in certain circumstances. These regulations allow recipients to utilize a noncompetitive procurement method if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing, we noted that for six out of eight procurement transactions tested, the Organization did not have documentation of the history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Questioned Costs: None Context: The history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price, was not documented for six of eight procurement transactions tested. Cause: The Organization stated that documentation of procurement procedures is not required for certain transactions due to the nature of the transaction based on their internal process. Effect: The Organization may not be in compliance with federal regulations for certain procurement transactions. Repeat Finding: Yes. Recommendation: We recommend that the Organization revise its procurement process so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Views of Responsible Officials: There is no disagreement with the audit finding.