Finding 585290 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-01-18

AI Summary

  • Core Issue: USTTI lacks a formalized procurement policy, which is necessary for compliance with federal regulations.
  • Impacted Requirements: This situation violates CFR 200.318, which mandates documented procurement procedures for non-Federal entities.
  • Recommended Follow-Up: USTTI should create and communicate a formal procurement policy, ensuring all procurement actions are documented and maintained properly.

Finding Text

Finding 2022-003: Procurement Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: We noted procurement procedures are outsourced to a third party and management is heavily involved in the ultimate decision. However, this policy is not formalized. Cause: USTTI did not have a documented formal procurement policy in place. Effect: A lack of a formal procurement policy is insufficient to meet the requirements noted in the Criteria section above. Questioned Costs: None. Context: USTTI does not have a formal procurement policy, and hence, not in compliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures, as well as substantive testwork over transactions above a defined threshold from select expense accounts that were charged to the Federal program. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend USTTI formalize a procurement policy to be in compliance with 2 CFR 200. We then recommend that USTTI management ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 8839 2022-002
    Significant Deficiency
  • 8840 2022-003
    Significant Deficiency
  • 8841 2022-004
    Significant Deficiency
  • 8842 2022-005
    Significant Deficiency
  • 8843 2022-002
    Significant Deficiency
  • 8844 2022-003
    Significant Deficiency
  • 8845 2022-004
    Significant Deficiency
  • 8846 2022-005
    Significant Deficiency
  • 8847 2022-002
    Significant Deficiency
  • 8848 2022-003
    Significant Deficiency
  • 8849 2022-004
    Significant Deficiency
  • 8850 2022-005
    Significant Deficiency
  • 585281 2022-002
    Significant Deficiency
  • 585282 2022-003
    Significant Deficiency
  • 585283 2022-004
    Significant Deficiency
  • 585284 2022-005
    Significant Deficiency
  • 585285 2022-002
    Significant Deficiency
  • 585286 2022-003
    Significant Deficiency
  • 585287 2022-004
    Significant Deficiency
  • 585288 2022-005
    Significant Deficiency
  • 585289 2022-002
    Significant Deficiency
  • 585291 2022-004
    Significant Deficiency
  • 585292 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.322 Economic Statecraft $745,418
19.700 General Department of State Assistance $472,297
11.553 Special Projects $289,000