2022-002 Procurement While the Organization has a procurement policy in place, it is noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The Organization has experienced substantial growth in recent years and in support of this expansion, hired an experienced CFO in early 2022. The new CFO identified the need for a compliant procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. To facilitate the adherence to the new procurement policy, the Organization has purchased new ERP software and both contracted with an outside organization and hired new internal staff to oversee the implementation of this software during 2023. The new procurement policy was reviewed by the auditors during the 2022 audit and a determination was made that had the new policy been in effect and followed, the Organization?s practices would have met the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. This policy will become effective on the go-live date of the new ERP software. A staff member has already been selected to oversee the procurement function and has completed a number of training courses specific to federal procurement requirements.