Finding 504474 (2024-002)

Criteria: Per procurement standards contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards (Uniform Guidance) Subpart D ‐ Post Federal Award Requirements Section 200.318, “nonfederal entities must use its own documented procurement procedures which reflect applicable State, local and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part.” Condition: The Board had appropriate procedures for procurement to conform to the requirements in the Uniform Guidance but did not have its policy in a written form. Cause: The Board’s internal controls over updating its policies for new regulations did not ensure a written procurement policy was in place in a timely manner. Effect: The Board’s procurement policy was not updated in a written form to conform to the new requirements of the Uniform Guidance. Auditor’s Recommendation We recommend management update its procurement policy to conform to the new requirements of the Uniform Guidance and implement monitoring procedures to ensure that policies conform with new regulations in a timely manner. Management Response: Management agrees with the finding and has provided the accompanying corrective action plan.