Finding Text
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition: We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. Questioned costs: Unknown. Context: During our testing, we noted the following exceptions: ? The Organization?s procurement policy did not meet the requirements defined by 2 CFR 200. ? The Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). ? For 7 out of 7 covered transactions, it was noted the Organization did not verify that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The Organization lacks a uniform Procurement, Suspension & Debarment policy that is in compliance with the Federal regulations and/or the terms and conditions of the Federal award. Effect: The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Repeat Finding: Yes ? 2021-002. Recommendation: ? We recommend the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements. ? We recommend the Organization retain all documentation and support to show that the procurement policy was followed. ? We recommend the Organization review, update, and implement the current Suspension and Debarment Process as there is no currently defined process to complete the Suspension and Debarment checks prior to entering into a covered transaction. Views of responsible officials: The Organization was unaware of the need to have its policy include thresholds for purchases using federal funds. We will work with the responsible parties to develop a purchasing policy that meets the federal purchasing requirements. The Organization will adopt a procurement policy in fiscal year 2023. Also, vendors have been reviewed for suspension and debarment and a vendor log with the information was completed in fiscal year 2023.