Finding Text
Finding 2022-009 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.318(c) specifies that "the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts." Condition and Context: During the test of the Organization's procurement, suspension, and debarment requirements, the Organization was not able to provide a written procurement policy. The Organization did not maintain a written policy related to procurement of goods and services related to the federal program which prohibits conflicts of interest and governs the actions of the Organization's employees engaged in the selection, award, and administration of contracts. The Organization did not maintain a written policy providing for disciplinary actions to be applied for related violations. The Organization does not maintain a written policy that requires that procurements incorporate a clear and accurate description of the procurement and identifies all requirements which the offerors must fulfill and other factors to be used in evaluating bids/proposals, and requires the Organization to ensure all prequalified lists are current and include enough qualified sources to ensure open and free competition. Cause and Effect: The Organization does not comply with the requirements of the Uniform Guidance related to written policies. However, we did not identify actual noncompliance with the procurement processes required by the Uniform Guidance. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement written policies in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.