Finding Text
Criteria The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in ??200.317 through 200.327. Condition The County did not have a written federal procurement policy and procedures throughout the majority of FY2022. The County adopted a written policy, in agreement with 2CFR200.318(a), on August 9, 2022. As of September 30, 2022, the adopted policy had not been fully implemented. Cause The County was unable to internally reconcile disagreements in the language for inclusion in the federal procurement policy and procedures document, leading to a delay in the approval and implementation of a written procurement policy. Effect The County would be out of compliance with the required procurement activities for purchases. Questioned Costs There are no questioned costs related to finding 2022-001. This is a general finding, rather than a finding related to a specific program. Perspective Information The County began working on a draft version of the written procurement policy in FY2021. The process of researching federal procurement requirements and reconciling the final language took longer than expected. Upon the adoption of the policy on August 9, 2022, the County began the implementation process. Within the language of the adopted policy are provisions which shall be vetted and discussed prior to taking effect. Such policies are noted as taking effect no later than August 4, 2023. This finding represents a systematic problem (as opposed to an isolated event), which is actively being resolved. Identification of Repeat Findings This is not a repeat finding. Recommendation We recommend the County expedite the provisions subject to vetting and begin following the written federal procurement policy and procedures. Views of Responsible Officials We agree with the audit finding and are taking corrective action to fully implement the policy on or before August 4, 2023. The county has officially formed an audit committee composed of the nine elected officials. The audit committee will review the federal procurement policy to ensure complete implementation.