Finding Text
Type of Finding: Significant Deficiency in Internal Control over Compliance
Federal Agency: Department of Veteran Affairs
Federal Program Name: VA Supportive Services for Veteran Families Program
Assistance Listing Number: 64.033
Federal Award Identification Number and Year: S20-WA-500-2023
Award Period: October 1, 2019 to September 30, 2023
Criteria or specific requirement: 2 CFR 200.318(i) states that "the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price". In addition, 2 CFR 200.320(a)(2)(i) states that "... If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity". 2 CFR 180.300 also indicates that participants must check SAM exclusions, collect a certification form, or add a clause or condition to the covered transaction before entering into a covered transaction.
Condition: For the sampled procurement selection, documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required, and stated in CCS’s written procurement policy. In addition, documentation was not retained for the vendor showing the vendor was checked for suspension and debarment prior to entering into the transaction.
Questioned costs: None
Context: CLA tested the entire population (1) of procurement transactions charged to the major program that exceeded CCS’s established Micro Purchase threshold of $10,000. The transaction was found to be out of compliance with the procurement requirements, as documentation was not retained detailing the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Documentation should be retained to evidence the adequate number of price comparisons, price analyses, and rationale of acquisition, including to limit competition where competition is limited. In addition, documentation was not retained for the vendor showing that the vendor was checked for suspension and debarment prior to entering into the transaction.
Cause: Documentation retained for the procurement transaction was not adequate to show proof of compliance with CFRs 200.318 – 200.327.
Effect: Without adequate records retained, CCS is at risk of noncompliance with the standards of procurement.
Repeat Finding: No.
Recommendation: CLA recommends updating the Procurement, Suspension and Debarment certification form to include more rigorous documentation as required by CFRs 200.318 – 200.327, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings, and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within CCS.
Views of responsible officials: There is no disagreement with the audit finding.