2022-001 PROCUREMENT Federal Assistance Listing Number: Higher Education Emergency Relief Fund (HEERF) 84.425F Criteria A non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The College must use its own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Observation/Condition/Context The College did not follow its procurement policy in one identified instance out of six tested. It was noted that the College did not solicit competitive price quotations for a purchase exceeding policy thresholds under the HEERF program. Questioned Cost There were no questioned costs associated with this finding. Cause/Effect Following the established procurement policy allows for cost comparison and the ability to evaluate whether a vendor is reputable and if the contract has all the required provisions. By not following the policy, the College opens itself up to higher costs and riskier transactions. Recommendation We recommend that the College implement a review process to identify potential instances of noncompliance with the College?s procurement policy. Planned Corrective Action ? The Business Office and Purchasing teams will amend our current procurement policy to reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. ? The Business Office and Purchasing teams will work with the college?s internal Administrative Information Systems staff to implement an additional review step in the Workday requisition process for the following qualified purchasing thresholds: o Micro-purchases under $10,000 would suggest sought out competitive vendors o Small purchases over $10,000 and less than $250,000 would require quotes o Formal procurement methods for purchases over $250,000 would require sealed bids Implementation Date Beginning July 1, 2023 Responsible Personnel Jacquelyn Craddock, Purchasing Manager Contact Information Email: jcraddock@cca.edu