Finding Text
Identification of Federal Program
21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria
2 CFR 200.320 Methods of procurement to be followed.
The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award.
2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate.
Condition
The County did not follow formal procurement procedures related to the purchase of jail camera system.
Cause
The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320.
Potential Effect
Open competition was not insured.
Questioned Costs
None
Context
The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed.
Identification of a repeat finding, if applicable
This is a new finding for the County
Recommendations
Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold.
Views of Responsible Officials
The County agrees with the finding and will develop a corrective action plan.