Finding Text
Finding 2023-002: Lack of Formal Procurement Policy That Reflects Federal Requirements
Federal Agency: U.S. Department of the Treasury
Federal Program: ARPA – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: March 15, 2022 to December 31, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance
Condition and Criteria: Non-federal entities are required to have documented procurement procedures that reflect applicable federal requirements that are indicated 2 CFR Section 200.317 through 200.327. Such a policy ensures an appropriate level of competition in making purchases from vendors depending on nature and size of the purchase. This policy would include written procedures for procurement transactions ranging from micro-purchases (i.e., generally under $10,000), small purchases where price or rate quotations should be obtained, and larger purchases where formal sealed bids or proposals should be obtained.
Cause: The Organization has formal a conflict of interest policy and its internal control procedures related to purchases require dual signatures for purchases in excess of $5,000. However, the Organization does not have a formal procurement policy that incorporates the requirements of 2 CFR Section 200.317 through 200.327.
Effect: The Organization could make purchases that involve pricing that has not been subjected to an appropriate level of competition or price analysis that has been documented.
Recommendation: We recommend that the Organization develop a formal documented procurement policy that incorporates the federal requirements indicated in 2 CFR Section 200.317 through 200.327 as discussed above.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. The Organization will adopt a formal procurement policy in accordance with federal requirements.
Name of the Contact Person Responsible for the Corrective Action: Paula Culp, Chief Administrative Officer
Planned Completion Date for the Corrective Action Plan: March 2024