Finding 372581 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-03-05
Audit: 293660
Organization: Think of US (DC)

AI Summary

  • Core Issue: The Organization did not follow updated procurement policies, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: CFR 200.320 mandates competitive bidding for purchases over $10,000, with limited exceptions for noncompetitive proposals.
  • Recommended Follow-Up: Ensure adherence to procurement guidelines and create a documentation form for the procurement process, including bids and decision details.

Finding Text

Finding 2022-002: Procurement Information on the Federal Program: 93.471 Criteria or Specific Requirement: CFR 200.320 specifies methods of procurement that must be used including competitive bidding where applicable, and limits the use of procurement by noncompetitive proposals to specific instances or situations including 1) the item is available only from a single source, 2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation, 3) the Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity, or 4) after solicitation of a number of sources, competition is determined inadequate. Condition: The Organization revisited their procurement policy following the completion of the fiscal year 2021 audit. As a result of the timing, vendors were hired prior to the integration of the updated procurement procedures and we noted instances where contractors were engaged in excess of the $10,000 procurement threshold, but adequate competitive bidding support was available. Cause: The Organization has not performed procedures in accordance with its procurement policies for certain purchases. Effect or Potential Effect: If procurement procedures are not followed, there is a risk that the Organization will not perform a proper evaluation of each element of cost to determine reasonableness. Questioned Costs: Undetermined Context: Our testwork consisted of statistical sampling as well as substantive testwork over various samples of expenditures, and were determined to be representative of the population for the fiscal year under audit. Identification as a Repeat Finding, if Applicable: See prior year finding 2021-005. Recommendation: We recommend that the Organization adhere to the current procurement guidelines, and also recommend that the Organization establish a form to document the procurement process, including bids received, conclusion, individuals involved and date.

Corrective Action Plan

Views of Responsible Officials: The sample was chosen prior to the implementation of our procurement policy. The procurement policy was updated after recommendations made in the audit completed in late 2022. Since the conclusion of 2022, our personnel have undergone comprehensive training on procurement procedures and have diligently adhered to the established guidelines as required.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 372580 2022-001
    Significant Deficiency Repeat
  • 949022 2022-001
    Significant Deficiency Repeat
  • 949023 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.471 Title IV-E Kinship Navigator Program (a) $1.33M