Criteria: According to 2CFR 200.318(i) the recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. The records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The School did not maintain records for a food vendor that met the simplified acquisition threshold for the year. Cause: The School's procurement policies do not address the frequency of which vendors should be evaluated. In addition, the policies also do not address records retention. Potential Effect: The procurement may not have been proper under the grant requirements.
Recommendation: We recommend that the School follow federal procurement guidelines for each of the different purchase thresholds for each vendor. We further recommend that the School retain any documentation created related to the procurement selection and vetting process. Action: As of the date of this exit conference, we will adopt the above recommendations, securing and retaining the appropriate documentation of vendor selection and retention.