Finding 479603 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-07-29
Audit: 316184
Auditor: Kmh LLP

AI Summary

  • Core Issue: The Council failed to maintain proper documentation for one procurement transaction, violating the requirement for full and open competition.
  • Impacted Requirements: This finding highlights non-compliance with 2 CFR 200.319 and the Council’s own procurement policy.
  • Recommended Follow-Up: The Council should ensure strict adherence to its procurement policy and improve documentation practices for future transactions.

Finding Text

Finding No.: 2023-001 Procurement Federal Agency: National Endowment for the Humanities Federal Assistance Listing No.: 45.129 Program: Promotion of the Humanities-Federal State Partnership Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency Federal award no. and year: SO-283113-22 Criteria: 2 CFR 200.319 requires all procurement transactions to be conducted in a manner providing full and open competition. The Council’s purchasing and procurement policy requires the Council to obtain and evaluate competitive bids to determine the vendor with the optimal qualities including price, availability, and quality, among other factors; and the documentation of this process. Condition: The Council did not maintain documentation within 1 procurement file to demonstrate that the procurement was conducted in a manner providing full and open competition. Context: We selected a non-statistical sample of 2 procurement transactions out of a population of 6 procurement transactions, and noted that the procurement file for 1 of our selections included documentation of the significant history of the procurement transaction, however was missing specific documentation to evidence that the procurement was conducted in a manner providing full and open competition. Cause: The Council has adopted a purchasing and procurement policy which requires documentation of each procurement transaction to support that it was conducted in a manner providing full and open competition, however the Council was not diligent in following this policy. Effect: Failure to properly adhere to the purchasing and procurement policy resulted in a lack of evidence to support that a procurement transaction was conducted in a manner providing full and open competition. Questioned costs: None Identification of a repeat finding: N/A Recommendations: The Council should diligently follow its existing policy. Views of Responsible Official(s) and Planned Corrective Action: Management concurs with the finding. See Corrective Action Plan.

Corrective Action Plan

Hawaiʻi Council for the Humanities Fiscal year ended Oct 31, 2023 Finding No.: 2023-001 Procurement July 15, 2024 Views of Responsible Official(s) and Planned Corrective Action: HCH concurs with the finding. Management notes additional context: HCH was dealing with staff shortage/transition at the time. Documentation was created but was not filed/kept appropriately. HCH can strengthen staff understanding of the policy as well as procedure for keeping documentation. Corrective action plan: Fiscal and Admin Assistant to create a formal filing system for procurement documentation. Executive Director and Deputy Director to review HCH procurement policies with all staff and with accountants. Person Responsible: Aiko Yamashiro, HCH Executive Director Anticipated Completion Date: Aug 1 2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1056045 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
45.129 Promotion of the Humanities_federal/state Partnership $902,401