Finding Text
Lack of Formally Adopted Procurement Policy
21.027 Coronavirus State and Local Fiscal Recovery Funds
(Significant Deficiency in Internal Control over Compliance)
(Section I – Procurement and Suspension and Debarment)
Condition: The Organization does not have a documented procurement policy in place.
Criteria: Per the Uniform Guidance Compliance Supplement, Section I, Procurement and
Suspension and Debarment, recipients are expected to have procurement policies and
procedures in place that comply with the procurement standards outlined in Title 2 CFR
Sections 200.317 through 200.327.
Cause: The Organization obtained their first federal funding as a result of the COVID-19
pandemic. The Organization did not have a documented procurement policy in place to meet
the criteria required under Uniform Guidance. As a result, even though expenditures over
$15,000 require additional approvals, no documented policy was in place during 2023.
Effect: Lack of a documented procurement policy could result in inappropriate vendor
preferences or conflicts of interest.
Recommendation: We recommend a formal written procurement policy be implemented that
complies with Uniform Guidance.
Management’s Response: See accompanying management’s corrective action plan.