Finding 246 (2023-002)

Condition: Significant Deficiency: The Organization's procurement policy does not contain the required provisions related to federal grant expenditures. Criteria: The Uniform Guidance imposes strict purchasing requirements on nonprofits expending non-payroll related federal funding. Cause: The Organization did not know that there were specific procurement policy requirements related to expenditures of federal funding. Effect: Purchases made by the Organization utilizing federal funding in excess of $10,000, in the aggregate, may not meet the Uniform Guidance requirements. However, in the testing performed in the sampled non-payroll expenditures, the Organization's procedures met the federal requirements even through not documented specifically in the procurement policy. Recommendation: We recommend that the Organization implement a separate procurement policy that is specific for federal grant expenditures that follows the Uniform Guidance requirements. Views of Responsible Officials and Correction Action: Refer to the Corrective Action Plan.