Finding Text
Condition: During the audit, we noted that a procurement policy meeting the minimum requirements
under 2 CFR 200.320 was not in place at the Organization.
Criteria: The Organization should have and use documented procurement procedures, consistent with
the standards for any method of procurement used for the acquisition of property or services required
under a Federal or sub-award.
Cause: The Organization received a new grant in 2021 and was therefore required to have a
procurement policy in place meeting the minimum standards under 2 CFR 200.320. The Organization
was unaware of the requirement and did not implement a policy.
Effect: Due to the condition above noted, the Organization did not follow procurement standards under 2
CFR 200.320 when acquiring services. However, most costs associated with the major program did not
require the acquisition of outside services.
Recommendation: The Organization should implement a procurement policy that meets the standards
requirement under CFR 200.320 and ensure that all relevant personnel are aware of and follow the
requirements in place.