Finding Text
Finding 2023-001
Significant deficiency in internal control over compliance with procurement procedures
Federal Agency: United States Agency for International Development
Program Titles: USAID Foreign Assistance for Programs Overseas
Assistance Listing Number: 98.001
Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084
Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026
Criteria
Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a 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. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis.
Condition/Context
In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922.
Cause
The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances.
Effect
Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy.
Questioned Costs
$38,922
Repeat Finding
No.
Recommendation
We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.