Finding Text
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.