Finding 520815 (2024-002)

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Requirement
I
Questioned Costs
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Year
2024
Accepted
2025-01-30
Audit: 340615
Auditor: Porte Brown LLC

AI Summary

  • Core Issue: The Organization failed to keep adequate records for procurement transactions as required by 2 CFR 200.318(I).
  • Impacted Requirements: Lack of documentation for procurement methods, contractor selection, and contract pricing undermines compliance with federal regulations.
  • Recommended Follow-up: Implement procedures to ensure all procurement decisions are documented, including quotes from qualified sources.

Finding Text

Criteria: The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity must maintain records sufficient to detail the history of each procurement transaction. These 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 Organization did not maintain sufficient documentation of its procurement decisions. Cause: The exception noted above was due a lack of documentation of the process followed by the Organization to ensure that all procurements of goods and services are in accordance with the Uniform Guidance and it’s procurement policy. Context: The population subject procurement requirements was one vendor under the small purchase threshold. The Organization did not maintain documentation of quotes from other qualified sources and document the selection of the vendor. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Recommendation: The Organization should ensure its procedures specifically include maintaining documentation of procurement decisions. Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Primo Center for Women and Children has immediately implemented an update to the existing procurement procedure to ensure complete records are maintained for all procurement activities, including quotes from other qualified sources and documentation of the bid selection process. The agency considers the Plan fully implemented and complete as of December 31, 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.569 Community Services Block Grant $958,049
14.276 Youth Homelessness Demonstration Program $928,069
14.231 Emergency Solutions Grant Program $798,498
93.493 Congressional Directives $366,509
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $247,991
14.267 Continuum of Care Program $155,561
93.110 Maternal and Child Health Federal Consolidated Programs $56,837
14.881 Moving to Work Demonstration Program $11,377