Finding Text
FEDERAL PROCUREMENT Criteria: 2 CFR sections 200.318 through 200.327 govern procurement standards for federal programs. Per these standards, a non-federal entity (the city) must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Also, no employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition: The city does not have a formal, written conflict of interest policy or procurement manual as required by 2 CFR section 200.318. Cause: Responsible officials were unaware of the requirement. Effect: Noncompliance with federal procurement standards. Recommendation: The city should develop a formal procurement manual that contains all elements necessary to comply with 2 CFR sections 200.318 through 200.327. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.