Finding Text
2022-001: Federal Procurement Standards Federal agency: U.S. Environmental Protection Agency Pass-through agency: None Title: Air Pollution Control Program Support Assistance Listing Number: 66.001 Award Year: 2022 Award Number: 97412920 Criteria: 2 CFR 200.303 requires the Department to establish and maintain internal controls over compliance with federal awards. 2 CFR 200.320 identifies the methods of procurement to be followed for acquisition of property or services required under a federal award or subaward. Condition and perspective: The Department recorded $69,375 of legal services to the federal award without following an approved method of procurement under 2 CFR 200.320. Legal services are exempt from state procurement law, but they are within the scope of federal procurement standards. Cause: The vendor provides in-house legal representation and regularly assists the Department with legal matters. Due to the long-standing, existing relationship, the vendor was selected for services related to the grant without following procurement standards. Effect: The Department posted $69,375 of legal services to the federal award without following federal procurement standards. Questioned Cost: $69,375. Recommendation: Management should ensure the Department follows federal procurement standards for all vendors paid with federal funds. Management?s response: Rate quotes will be obtained from at least three (3) law firms as required for ?small purchases? by 2 C.F.R. 200.320.