Finding Text
2025-004 Procurement Policy Criteria: Under 2 CFR §200.318 through 200.327, General Procurement Standards, a non-federal entity must use and document procurement procedures for the acquisition of property or services required under a federal award or subaward. Additionally, the non-federal entity must include policies and procedures related to competition, informal and formal procurement methods, and noncompetitive procurement known as sole source. 2 CFR §200.214, Suspension and Debarment, requires entities to verify that vendors are not suspended or debarred from participating in federal funds. Condition: There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures; no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed; and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Context: We tested all procurement transactions totaling $863,741. All transactions tested lacked documentation to demonstrate compliance with the applicable procurement requirements of the Uniform Guidance. Cause: Management had not established and formally adopted procurement policies and procedures consistent with Uniform Guidance requirements during the audit year. Effect: Without documented procurement policies, there is an increased risk that procurements may not be conducted in accordance with Federal requirements, resulting in potential noncompliance with the Uniform Guidance. Charges relating to vendor services and sub-awards that were charged to the federal award may not be in accordance with the specific compliance requirements of the Uniform Guidance. Recommendation: We recommend that management develop, formally adopt, and implement written procurement policies and procedures that comply with the procurement standards in 2 CFR §200.317 through 200.327 and provide training to personnel responsible for purchasing. We also recommend the Organization to adopt policies that incorporate the requirements of 2 CFR §200.214 regarding suspension and debarment regulations. We also recommend that a review of all existing vendor contract filed be performed to ensure that the documentation, as required by the Uniform Guidance, is maintained in the files.Views of Responsible Officials and Planned Corrective Actions: The Organization is in the process of developing a corrective action plan and provide personnel training.