Finding 1238662 (2025-001)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2026-09-30

Audit: 413589

Organization: NATIONAL PRESERVATION INSTITUTE (VA)

Auditor: MULLINS PC

AI Summary

Core Issue: The Institute lacks formal written procurement policies, leading to missing documentation in the procurement process.
Impacted Requirements: Non-compliance with 2 CFR Section 200.318 and related procurement standards.
Recommended Follow-Up: Review and enhance procurement processes to ensure all documentation is retained and implement a formal written procurement policy.

Finding Text

Finding 2025-001: Procurement – Significant Deficiency Assistance Listing Number: 12.632 Criteria: 2 CFR Section 200.318 requires that the non-federal entity must have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity’s documented procurement procedures must conform to the procurement standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition: During testing of the Institute’s controls over procurement and compliance with procurement requirements, we identified instances where the Institute did not have all the needed documentation around the procurement process. Cause: The Institute did not have formal written procurement policies and procedures during the year to ensure compliance with applicable Federal procurement requirements. Effect: The Institute was not fully compliant with the procurement requirements of the Uniform Guidance. Questioned costs: None Repeat Finding: No. Recommendation: We recommend the Institute review its current processes and controls over procurement to ensure all required documentation is retained and available and implement a formal written procurement policy. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

The National Preservation Institute acknowledges the finding related to procurement documentation. While the National Preservation Institute believes its procurement activities were conducted in a manner consistent with Federal requirements, certain documentation necessary to demonstrate compliance was not retained in a manner that readily supported the procurement decisions. Management has reviewed the circumstances surrounding the finding and has reinforced expectations regarding procurement documentation, record retention, and compliance with Federal procurement requirements. Going forward, procurement files associated with federally funded activities will be reviewed to ensure that all required supporting documentation is generated and retained, including documentation supporting the basis for contractor selection, cost or price analyses, procurement method, and any other records required by Uniform Guidance. In addition, the National Preservation Institute will formally adopt a procurement policy designed to align with the procurement standards contained in Uniform Guidance, including requirements related to competition, conflict of interest, documentation, contractor selection, and procurement record retention. Management believes that the combination of a formal procurement policy and enhanced review procedures will strengthen compliance with Federal procurement requirements and ensure that procurement files contain sufficient documentation to support future monitoring, audit, and reporting requests.

Other Findings in this Audit

1238663 2025-002

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
12.632	DEPARTMENT OF WAR ENERGY, INSTALLATIONS, AND ENVIRONMENT INNOVATION PROGRAMS	$2.47M