Finding Text
Criteria or Specific Requirement
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions.
Condition and Context
We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exception:
• For two of the five procurement transactions tested the Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.).
Effect
The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors.
Questioned Costs
None identified.
Cause
The Organization lacked a process to ensure all supporting procurement documentation is retained to support the procurement method used.
Recommendation
We recommend the Organization retain all documentation and support to show that the procurement policy was followed.
Views of Responsible Officials
The Organization does have a policy for Procurement, Suspension, and Debarment. The procurement documents were misfiled and staff have not been able to locate the documents. The Organization provided education to staff on the importance of retention of records and ensuring documents are filed in the correct folders.