Core Issue: The Institute lacks a documented procurement policy, violating 2 CFR 200.318 requirements.
Impact: This oversight puts the Institute out of compliance with federal guidelines, despite no questioned costs.
Recommended Follow-Up: Implement procurement policies and review them annually for potential improvements.
Finding Text
Condition and Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures for the acquisition of property or services required under a federal award or subaward. The Institute does not have a documented procurement policy. Cause: The Institute does not make significant purchases of goods or services and therefore the lack of a procurement policy was an administrative oversight. Effect: The Institute is not in compliance with the requirements of the Uniform Guidance. Questioned Costs: There were no questioned costs associated with this finding. Identification of a Repeat Finding: This is not a repeat finding. Auditors? Recommendation: We recommend the Institute implement procurement policies and evaluate these procedures on an annual basis to determine if additional enhancements should be made or new policies created. Views of Responsible Officials: See attachment for the Institute?s corrective action plan.
Corrective Action Plan
Corrective Action Plan: The Organization will have the Board approve a written procurement policy that satisfies the Uniform Guidance requirements. Anticipated Corrective Action Plan Completion Date: Ongoing. Contact Information: For additional information regarding this finding please contact Aina Vilumsons, Executive Director, at 414-270-3600.