Finding 32301 (2022-004)

Criteria: 2 CFR Part 200.318(a) requires the entity have written procurement policies and procedures. Condition: While Lakewood Theatre Company has internal procurement policies and procedures, these do not meet the requirements of 2 CFR Part 200.318(a). Cause: Administration did not have written procedures over procurement which meet the requirements of 2 CFR Part 200.318(a). Effect: Unallowable costs could be charged to the program. Questioned Costs: None Recommendations: Management should modify their written procedures as required by 2 CFR Part 200.318(a). Views of Responsible Officials: Management notes that, as this is their first time receiving significant federal funding and this was one-time emergency funding rather than an ongoing award, they do not have these procedures in writing. However, they reviewed the award guidelines, obtained multiple bids, and adhered to their internal conflict of interest policy in the selection of vendors. While they do not anticipate receiving federal funding in the future, if this does occur, they will develop written procedures at that point.