Finding 2023-004 – Procurement Policy
Criteria:
In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards",
the non-federal entity must have and use documented procedures, consistent with State, local,
and tribal laws and regulations and the standards of this section, for the acquisition of property or
services required under a federal award or subaward. The non-federal entity's document
procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 -
§200.327.
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's
Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327
Questioned Costs:
None
Cause:
The Coalition was unaware of the changes in General Procurement Standards within Uniform
Guidance and therefore does not have sufficiently established control policies and procedures to
comply with 2 CFR, Part §200.317 - §200.327.
Effect:
The Coalition does not have the ability to determine if disbursements, projects, and bids comply
with 2 CFR, Part §200.317 - §200.327.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 -
§200.327. and establishes appropriate internal control policies and procedures related to
procurement and that all staff be trained in those policies and procedures, so they are familiar
with the requirements. We further recommend no contract or agreement be awarded by the
Coalition in which appropriate procurement policies have not been followed
Corrective Action: In response to the finding regarding non-compliance with procurement policies as outlined in 2 CFR, Part §200.317 - §200.327, the Coalition will take the following corrective actions:
1. Review and Update Procurement Policies:
o The Coalition will conduct a comprehensive review of its current procurement policies and procedures. We will update these policies to ensure full compliance with Uniform Guidance 2 CFR, Part §200.317 - §200.327, as well as any relevant state, local, and tribal laws and regulations.
o We will review and update detailed procedures. These procedures will be clearly aligned with the standards identified in 2 CFR, Part §200.317 - §200.327.
2. Training and Education:
o All staff involved in the procurement process will receive training on the updated procurement policies and procedures. This training will ensure that all relevant personnel are familiar with the requirements of Uniform Guidance 2 CFR, Part §200.317 - §200.327, and understand their responsibilities in adhering to these standards.
3. Implementation of Internal Controls:
o The Coalition will implement internal controls to ensure compliance with the updated procurement policies and procedures. This will include establishing a review and approval process for all procurements to verify adherence to the new standards.
4. Monitoring and Compliance Checks:
o We will establish a system for ongoing monitoring and compliance checks to ensure that all disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Quarterly audits will be conducted to identify and address any deviations from the established policies and procedures.
Timeline for Implementation: The corrective actions outlined above will be implemented within the next 30 days. The review and update of procurement policies and procedures will be completed within this period, and training sessions for relevant staff will be conducted immediately following the implementation of these changes. Internal controls and monitoring systems will be established concurrently.
Contact Information: For further information or questions regarding this corrective action plan, please contact: Carlett Gregory, CFO, Email: cgregory@nuihc.com, 402-346-0902 x 204.
Carlett Gregory
Carlett Gregory
CFO