Finding Text
Finding: 2023-001 Procurement
Information on the Federal Program: Assistance Listing Number 16.582
Criteria: Under 2 CFR 200.318, a recipient of U.S Government funds must use their own
documented procurement procedures which reflect applicable Uniform Guidance requirements to
procure goods and services in order to ensure that all purchases are conducted in a manner that
provides full and open competition.
Condition: The Association did not perform and document adequate procurement procedures over
qualifying purchases using Federal funds.
Cause: The Association's internal policies and procedures governing procurement were not
consistently applied.
Effect: Purchases of goods and services could be made above prevailing market rates if the
prescribed procurement procedures are not adhered to, and thus, there lies the potential that the
Association will not receive the best value for its purchases. The procurement process also allows for
the evaluation of potential conflicts of interest with prospective vendors and contractors. Failure to
perform the proper procurement procedures could result in disallowance of Federal expenditures
based on lack of fair competition.
Questioned Costs: None noted.
Context: Our audit procedures consisted of testwork completed on individual expenditures charged
to the Federal awards. The report in which samples were selected was generated directly from the
Association's accounting system. We consider our sample to be representative of the population. The
condition appeared to be systemic in nature.
Identification as a Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that all procurement records for purchases in excess of the
purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or
(b) justification for lack of competition when competitive bids or offers are not obtained. Additionally,
the conclusion should be clearly documented and accompanying the procurement documentation.