Finding 398463 (2023-001)

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 §§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.  Additionally,  non‐federal  entities  are  prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in  the  transaction.  This  verification  may  be  accomplished  by  checking  the  System  of  Award  Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate  internal  controls  over  its  procurement  procedures  to  ensure  compliance  with  Uniform  Guidance regulations and guidelines were not in place. The YWCA did not have Board adopted policies over procurement with federal dollars. The YWCA did not meet the requirement to verify that  covered  transactions  were  only  made  to  an  entity  that  was  not  suspended  or  debarred  or  otherwise excluded. Lastly, the YWCA did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The YWCA’s internal controls over procurement of goods and services were not adequate. Effect The YWCA was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment or procurement. Context During our review of procurement, we noted the following: - The YWCA did not have formal written procedures over procurement. - For one purchase reviewed over $10,000, the YWCA did not go through formal procurement. There was no formal documentation maintained by the YWCA to show prior‐purchase authorization being granted. - For one purchase reviewed over $25,000, the YWCA did not perform a vendor check for suspension and debarment. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The YWCA should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.