Finding Text
2023-001 Procurement: Implement Procurement Policy Guidelines.
Federal Program Information: Farmers Market and Local Food Promotion Program (Assistance
Listing 10.175 and Soil and Water Conservation Program (Assistance Listing 10.902)
Condition and Criteria: Federal guidelines require all entities to have written procedures for
procurement transactions that ensure clear and accurate description of the technical requirements
for material, products, or services. The procurement policy must define the number of quotes to
obtain and the manner in which quotes should be obtained. Federal guidelines define three types
of procurements: micro-purchases, items less than $10,000 which require no extensive
documentation of procurement history; small purchases, items not to exceed $250,000 which
require price and rate quotes from multiple qualified sources, and purchases greater than
$250,000, for which the Organization must obtain sealed bids or competitive proposals. The
Organization did not have a procurement policy in place to cover the full fiscal year.
Prior Year Audit Finding: 2022-002
Cause and Effect: The Organization’s procurement policy was not adopted until December 2023.
This has resulted in improper supporting documentation for all purchases greater than the micropurchase
threshold of $10,000 prior to that date.
Context: For the year ended December 31, 2023, there was no purchases procurement identified
that exceeded the micro-purchase threshold.
Questioned Costs: None.
Recommendation: The Organization adopted the procurement policy in December 2023. To
maintain compliance with this federal regulation and all other federal regulations, we recommend
for the policies and procedures to be reviewed on a regular basis to ensure there are no changes
in federal requirements and that the policies and procedures are still adequate for the staffing and
operations of the Organization.
Management’s Response: Management is in agreement that the Organization’s policy did not
properly reflect the Uniform Guidelines standards for procurement since the policy did not cover
the full fiscal year. Management has implemented the policy effective December 2023 and will
review and update the policy on a regular basis.