Finding Text
Condition: The Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance. Criteria: OMB Uniform Guidance ?200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in ?200.317 through ?200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. 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. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicity comply with the standards in 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. The Organization did not comply with the procurement standards concerning suspension and debarment (see finding 2022-002) and documentation of procurement activities (see finding 2022-003). Recommendation: A written procurement policy and a written standard of conduct should be established in accordance with the procurement requirements contained in Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: 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.