Core Issue: The Village's procurement policy allows waiving bidding requirements, which does not align with federal guidelines.
Impacted Requirements: Noncompliance with Uniform Guidance procurement standards could lead to issues with federal funding.
Recommended Follow-Up: Update the procurement policy to eliminate the bidding waiver for federal procurements, as agreed by management.
Finding Text
Assistance Listing #: 20.205 Program: Highway Planning and Construction Cluster Federal Agency: Department of Transportation Repeat Finding: Yes (2021-006) 2022-004 Procurement Policy In Need of Updating for Federal Requirements Criteria Uniform Guidance procurement requirements (2 CFR 200.320(c)) provides specific circumstances in which noncompetitive procurement can be used. Condition The Village?s procurement policy allows for waiver of bidding requirements by a 2/3 vote of all Village Trustees. This is not one of the specific circumstances provided in Uniform Guidance for noncompetitive procurement. Context We have not identified any instances in which bidding requirements have been waived for procurements under federal programs at this time. Cause The cause appears to be a lack of familiarity with the particular provision of the Uniform Guidance. Effect A procurement policy not in accordance with federal requirements could result in noncompliance with federal procurement requirements. Recommendation We recommend that the Village update its procurement policy to remove the bidding waiver provision in the case of federal procurements. Management Response Management agrees with the finding and recommendation. See corrective action plan.