Finding Text
Condition: ASP does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: ASP hasn?t been subject to the Uniform Guidance single audit requirements during recent fiscal years and while having various components of policies in places, has not adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Context: Several Uniform Guidance procurement requirements were not noted in ASP?s procurement policy. Questioned Costs: N/A Recommendation: ASP should prepare a revised policy for procurement procedures to more closely align with Uniform Guidance requirements. Repeat Finding: No. Management?s Response: ASP had updated our written procurement policies and procedures to comply with the December 2018 Uniform Guidance. However, we will review and write a more detailed version of those policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.