Finding Text
2022-001 Federal Agency: U.S. Department of Justice Federal Programs: Juvenile Mentoring Program Pass-Through Agency: Office of Justice Programs / Office of Juvenile Justice and Delinquency Prevention CFDA Number: 16.726 Award Period: January 1, 2019 ? September 30, 2023 Type of Finding: ? Compliance ? Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance section 200.320 described five general procurement standards that cover the purchase of property, supplies and services which include the following: (a) the Organization must maintain written policies for procurement covering the methods available under these regulations, (b) costs must be reasonable and necessary, (c) must provide for full and open competition, (d) the Organization must maintain written standards of conduct covering internal and external conflicts of interest, and (e) the Organization must maintain documentation addressing costs and price analysis and vendor selections where applicable based on the method of procurement used. Condition and Context: In our procurement test, we had observed that management has not properly implemented both a procurement and conflict of interest policy, but as part of the requirements under Uniform Guidance, the Organization has not implemented a procedure to address costs and price analysis of vendors having dollars expended by the federal program. This would include the tracking of quotations from multiple vendors, maintaining of vendor files, and the use of minority vendors. Questioned Costs: None Cause: Beginning January 1, 2018, the Office of Management and Budget had implemented the procurement standard under Uniform Guidance, management has not implemented its procurement policy under the new Uniform Guidance. Since the Organization had not added any large vendors during the year, management had not implemented a procedure over its current vendors who have some of their payments from federal funds, especially vendors whose costs were identified as small purchases. Effect: Not implementing the procurement standard in accordance with Uniform Guidance section 200.320 could lead the potential request back of funds from a federal or pass-through agency. Recommendation: We recommend management have a new policy established and approved by the board of directors. Views of Responsible Offices and Corrective Action Plan: Please refer to the Eluna?s Corrective Action Plan.