Finding Text
Finding 2024-001
The U. S. Code of Federal Regulations Title 2, Part 200.320, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must have and use documented procurement procedures. If purchases are made that fall within the small purchase thresholds defined in the Uniform Guidance, price or rate quotations much be obtained from an adequate number of qualified sources. Board policy 3.20.5 states that procurement transactions for federal programs that are not subject to the state procurement laws but exceed the aggregate amount of the federal micro-purchase threshold, will be obtained by utilizing price or rate quotes from two or more qualified sources. The Lawrence County Board of Education (the “Board”) expended $152,825.25 of Special Education – Grants to States funds for therapy services and did not provide documentation that price or rate quotations were obtained. The Board did not follow their procurement policies or the Uniform Guidance regarding this purchase. As a result, the Board did not comply with the Uniform Guidance procurement requirements. This finding was previously reported as Finding 2023-001.
Recommendation:
The Board should comply with the U.S. Code of Federal Regulations Title 2, Part 200.320 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) when entering into contracts that are within the small purchase threshold.