Finding Text
Criteria: In accordance with 2 CFR §200.320, federal procurement standards require non-
Federal entities to follow documented procedures that promote full and open
competition. For small purchases between $10,000 and $250,000, price or rate
quotations must be obtained from at least three qualified sources. Purchases
exceeding $250,000 must undergo formal procurement procedures such as sealed
bidding or competitive proposals.
Condition: During our testing of procurement transactions, we identified two vendors with
individual purchases exceeding the small purchase threshold of $10,000 for
which no documentation of competitive quotes was obtained. Additionally, one
vendor exceeded the $250,000 threshold for which a formal competitive
procurement process, such as sealed bids or proposals, was not conducted.
Cause: While the Organization had a procurement policy aligned with federal
requirements, the policy was not effectively enforced throughout the year.
Possible effect: The Organization risked overpaying for goods or services and may not have
achieved the best value for federal expenditures.
Questioned cost: $325,883 – Represents the total expenditures with the three identified vendors
during fiscal year 2024.
Recommendation: We recommend the Organization enhance its internal controls over procurement
by implementing a pre-procurement review process and staff training to ensure
consistent compliance with federal procurement thresholds and documentation
requirements.
Views of responsible officials:
Management agrees with the finding and will implement procedures to ensure
procurement compliance.