Finding Text
Condition: The Organization did not maintain documentation of its procurement decisions. Criteria: OMB Uniform Guidance ?200.320 details various methods of procurement to be followed based on the intended dollar value and nature of the contract. While the specific required documentation may vary based on each of the five methods, all mandate specific documentation concerning procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2022-001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware of the specific documentation requirements under the Uniform Guidance. Effect: In the absence of a written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization's written procurement policies should include details of required documentation in accordance with the Uniform Guidance, and the Organization should maintain such documentation. Views of Responsible Officials and Planned Corrective Actions: While documentation was not maintained, the procurement methods followed by the Organization did comply with the requirements based on the sizes of the contracts. Written procurement and conflict of interest policies, in accordance with the Uniform Guidance, will be established and implemented during the year ended June 30, 2023.