Finding 42213 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-07

AI Summary

  • Core Issue: One out of 19 procurement transactions lacked required documentation, violating federal regulations.
  • Impacted Requirements: Federal rules mandate detailed records for procurement methods, contractor selection, and pricing rationale.
  • Recommended Follow-Up: Revise procurement policy to ensure compliance with federal documentation requirements for all transactions.

Finding Text

Criteria or Specific Requirement: Federal regulations require recipients of federal funds to document the history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Federal regulations also specific certain procurement methods that recipients must use in certain circumstances. These regulations allow recipients to utilize a noncompetitive procurement method if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing, we noted that for one out of 19 procurement transactions tested the Organization did not have documentation of the history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Questioned Costs: None Context: The history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price was not documented for one of 19 procurement transactions tested. Cause: The Organization?s procurement policy states that procurement procedures are not required for certain transactions due to the nature of the transaction. Effect: The Organization may not be in compliance with federal regulations for certain procurement transactions. Repeat Finding: No. Recommendation: We recommend that the Organization revise its procurement policy so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.

Corrective Action Plan

Recommendation: We recommend that the Organization revise its procurement policy so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: AFAAC management will complete a review of the current AFAAC procurement policy to ensure the policy applies to all transactions. The policy will be modified to ensure that purchasing thresholds and procurement methods are in compliance with federal regulation when applicable. Going forward procurement documentation required by federal regulations will be retained. Names of the contact persons responsible for corrective action: David Laverentz Planned completion date for corrective action plan: March 31, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 42212 2022-002
    Material Weakness
  • 618654 2022-002
    Material Weakness
  • 618655 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
12.801 Air Force Academy Athletic Programs $13.24M