Finding 375746 (2023-004)

Finding 2023 - 004 Procurement - Native Hawaiian Education – Assistance Listing 84.362A Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). Condition: Procurement documentation for one vendor tested was not prepared and/or retained to support compliance with the regulations above and the School’s procurement policy. Context and Cause of Condition: Although the School has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Potential Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Recommendation: We recommend management monitor established procurement policies in place to ensure that sufficient documentation is maintained. Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.