Finding Text
Finding 2022-003: Internal Control and Compliance over Procurement Federal Agency: Department of the Treasury Program: Coronavirus State and Local Fiscal Recovery Funds: 21.027 Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.237, EC3 is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Condition: EC3 could not provide evidence that the purchase of 300 laptops for an aggregate purchase price of $362,004 followed formal procurement procedures. The purchase exceeded both the $30,000 procurement threshold for competitive bids set by EC3?s purchasing policy and the Uniform Guidance simplified acquisition threshold of $250,000. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: EC3 was not in compliance with the procurement requirements of the Uniform Guidance. Questioned costs: $362,004 based on invoice for purchase of 300 laptops applied to the program. Recommendation: We recommend that EC3 establish procedures to ensure that their purchasing policy is followed including the use of competitive bids or proposals, when appropriate.