In responding to the findings of the audit regarding the absence of a documented procurement
policy that aligns with federal statutes and procurement requirements as outlined in 2 CFR Part
200, Sigma Beta Xi, Inc. acknowledges the criticality of this oversight. We understand the
importance of having formal, documented policies in place to guide our procurement processes,
ensuring they are transparent, equitable, and in full compliance with federal regulations. The
absence of such documentation represents a missed opportunity for our organization to
institutionalize best practices and safeguard the integrity of our procurement activities.
Corrective Actions and Commitments:
Please let it be known prior to completion of our 2023 audit we were still in the process of
finalizing our 2022 audit. Therefore, it was not a matter of willful intention in not being compliant
with the Federal mandated guidance policy for Procurement and Suspension and Debarment,
but a matter of timing. Research of our vendors was in the process for 2023, but documentation
of the research was not being recorded.
To address this finding and prevent future occurrences, Sigma Beta Xi, Inc. has taken the
following steps:
1. Policy Development: We are in the process of developing a comprehensive procurement
policy that will be fully documented and accessible. This policy will outline the procedures for all
procurement activities, ensuring they are consistent with the requirements set forth in 2 CFR
sections 200.318 through 200.326. It will reflect applicable state and local laws and regulations,
as well as conform to applicable federal statutes and procurement requirements.
2. Stakeholder Engagement: Recognizing the importance of stakeholder buy-in, we will
involve key personnel from various departments in the development of the procurement policy.
This collaborative approach ensures the policy is comprehensive, practical, and adheres to the
diverse needs of our organization while maintaining compliance with federal regulations.
3. Training and Implementation: Upon completion and approval of the procurement policy, we
will conduct training sessions for all relevant staff. These sessions will cover the details of the
policy, emphasizing the importance of compliance with federal statutes and the procurement
requirements identified in 2 CFR Part 200. This will ensure that all team members are
knowledgeable about the policy and understand their roles and responsibilities within the
procurement process.
4. Monitoring and Compliance: We will establish mechanisms for monitoring compliance with
the new procurement policy. This includes regular audits of procurement activities and ongoing
reviews of the policy to ensure it remains current with federal regulations and best practices.
5. Documentation and Transparency: All procurement activities, especially those exceeding
the simplified acquisition threshold, will be thoroughly documented, including the rationale for
the procurement method used, selection of contract type, contractor selection or rejection, and
the basis for the contract price. This documentation will ensure transparency and accountability
in our procurement processes.
Sigma Beta Xi, Inc. is committed to rectifying this deficiency by not only developing and
implementing a documented procurement policy but also by fostering a culture of compliance
and continuous improvement. We view the audit findings as an opportunity to enhance our
operational effectiveness and ensure that our procurement practices fully support our mission to
break the cycle of poverty and violence through mentoring, education, and community
organizing. Our dedication to upholding the highest standards of integrity and transparency in all
our operations is unwavering, as we continue to empower future professional leaders in every
community we serve.