Finding 41644 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-25

AI Summary

  • Core Issue: The Organization's procurement policy does not meet federal guidelines, lacking necessary procedures for clear and competitive procurement transactions.
  • Impacted Requirements: The policy fails to address documentation for purchases over $10,000 and does not define the required number of quotes for small purchases.
  • Recommended Follow-Up: Update the procurement policy to align with federal Uniform Guidance guidelines to ensure compliance and proper documentation.

Finding Text

Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), 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?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.

Corrective Action Plan

2022-002 Procurement Management is in agreement that the RAFI?s current financial policies do not properly reflect Uniform Guidelines standards for procurement. The Managing Director of Operations and Executive Director will review RAFI?s financial policies and revise them as necessary by October 31, 2023 in accordance with federal regulations.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 41643 2022-001
    Significant Deficiency
  • 41645 2022-001
    Significant Deficiency
  • 41646 2022-002
    Significant Deficiency
  • 41647 2022-001
    Significant Deficiency
  • 41648 2022-002
    Significant Deficiency
  • 41649 2022-003
    Significant Deficiency
  • 618085 2022-001
    Significant Deficiency
  • 618086 2022-002
    Significant Deficiency
  • 618087 2022-001
    Significant Deficiency
  • 618088 2022-002
    Significant Deficiency
  • 618089 2022-001
    Significant Deficiency
  • 618090 2022-002
    Significant Deficiency
  • 618091 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.902 Soil and Water Conservation $168,038
10.215 Sustainable Agriculture Research and Education $139,799
10.331 Food Insecurity Nutrition Incentive Grants Program $107,269
10.147 Outreach Education and Technical Assistance $74,280
10.310 Agriculture and Food Research Initiative (afri) $71,986
10.234 American Rescue Plan Technical Assistance Investment Program $49,574
10.175 Farmers Market and Local Food Promotion Program (b) $30,658
10.307 Organic Agriculture Research and Extension Initiative $10,679
10.500 Cooperative Extension Service $10,067