Finding Text
Criteria: Under 2 CFR ?200.318, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, ?200.213 states non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition: During audit procedures performed, we noted that the Chamber does not have a specific policy on procurement or suspension and debarment, and does not have procedures in place to ensure that it complies with federal procurement requirements. Questioned Costs: Unknown Context: The Chamber lacks specific policies on procurement or suspension and debarment, and does not have procedures in place to ensure compliance with federal procurement requirements. Cause: The Chamber was unaware of the policy requirements as this is the first single audit the Chamber has been through in addition to the speed in which the funds were spent due to COVID-19 and the emergency it created for businesses in the area. Effect: Failure of the Chamber to comply with the audit requirements may constitute a violation of the contract and may result in the withholding of future payments. Recommendation: We recommend that the Chamber adopt a procurement and suspension and debarment policy that is in accordance with the requirements established by the Uniform Guidance. Furthermore, we recommend that these policies are approved by the board of directors. Views of responsible officials: There is no disagreement with the audit finding.