Condition:
The Organization does not have a documented procurement policy that conforms to applicable
federal statutes and the procurement requirements identified in 2 CFR Part 200.
Context:
During the year, the Organization made a purchase of property that was greater than the Simple
Acquisition Threshold of $250,000. As part of the audit procedures, we requested the
Organization's documented procurement policy. The Organization did not have a documented
procurement policy. Prior to making purchases in excess of the simplified acquisition threshold,
the Organization performed a price analysis in a manner consistent with 2 CFR Part 200.
Cause:
The Organization was not aware that a documented procurement policy was required. Criteria:
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Effect:
Without documented procurement policies, the Organization could procure assets in a manner that is not consistent with 2 CFR Part 200.
Recommendation:
We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318 through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and procurement requirements.
Management Response:
In responding to the findings of the audit regarding the absence of a documented procurement policy that aligns with federal statutes and procurement requirements as outlined in 2 CFR Part 200, Sigma Beta Xi, Inc. acknowledges the criticality of this oversight. We understand the importance of having formal, documented policies in place to guide our procurement processes, ensuring they are transparent, equitable, and in full compliance with federal regulations. The absence of such documentation represents a missed opportunity for our organization to institutionalize best practices and safeguard the integrity of our procurement activities.
Corrective Actions and Commitments:
To address this finding and prevent future occurrences, Sigma Beta Xi, Inc. is taking the following steps: 1. Policy Development: We are in the process of developing a comprehensive procurement policy that will be fully documented and accessible. This policy will outline the procedures for all procurement activities, ensuring they are consistent with the requirements set forth in 2 CFR sections 200.318 through 200.326. It will reflect applicable state and local laws and regulations, as well as conform to applicable federal statutes and procurement requirements.
2. Stakeholder Engagement: Recognizing the importance of stakeholder buy-in, we will involve key personnel from various departments in the development of the procurement policy. This collaborative approach ensures the policy is comprehensive, practical, and adheres to the diverse needs of our organization while maintaining compliance with federal regulations. 3. Training and Implementation: Upon completion and approval of the procurement policy, we will conduct training sessions for all relevant staff. These sessions will cover the details of the policy, emphasizing the importance of compliance with federal statutes and the procurement
requirements identified in 2 CFR Part 200. This will ensure that all team members are
knowledgeable about the policy and understand their roles and responsibilities within the
procurement process.
4. Monitoring and Compliance: We will establish mechanisms for monitoring compliance with the new procurement policy. This includes regular audits of procurement activities and ongoing reviews of the policy to ensure it remains current with federal regulations and best practices.
5. Documentation and Transparency: All procurement activities, especially those exceeding the simplified acquisition threshold, will be thoroughly documented, including the rationale for
the procurement method used, selection of contract type, contractor selection or rejection, and the basis for the contract price. This documentation will ensure transparency and accountability in our procurement processes.