Finding Text
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.