Finding 577732 (2022-003)

2022-003 Material Weakness in Compliance and Internal Control over Compliance - Procurement, Suspension, and Debarment Standards Identification of federal program: 84.356 Alaska Native Educational Programs Criteria or specific requirement: Uniform Guidance 2 C.F.R 200.318 through 2 C.F.R. 200.327 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: It was noted during the audit that although Learning Point Alaska, Inc. (LPA) has documented procurement policies consistent with Uniform Guidance, LPA did not maintain evidence that it followed its own documented procurement policy for procurements greater than the micropurchase threshold. Cause: LPA does not have an administrative process to ensure that the procurement documentation supporting purchases greater than the micropurchase threshold are maintained in accordance with LPAs procurement policies. Effect or potential effect: LPA is out of compliance with Uniform Guidance procurement standards. Questioned Costs: None Context: For this program, five procurements were tested that exceeded LPA’s micro-purchase threshold. Of the five procurements tested against LPA’s procurement policy, one did not have documentation supporting LPA followed their procurement policy. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of LPA’s internal control structure over compliance with Uniform Guidance, that LPA prepare a checklist, reflective of LPA’s approved procurement policies, that must be completed before procurements can be awarded and all documents supporting that checklist be filled together. Views of Responsible Officials: Management agrees with the finding and has set up a corrective action plan. Refer to Corrective Action Plan.