Finding Text
Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Title 2 U.S. Code of Federal Regulations (CFR) sections 200.318 through 200.236. 2 CFR section 200.318(a) indicates the non-federal entity's documented procurement procedures must conform to the procurement standards identified in these sections. The general requirements are that the Organization maintain written standards of conduct, full and open competition, and methods of procurement to be followed including formal and informal procurement processes based on a defined threshold. Condition: The Organization lacks a documented procurement policy, therefore the procurement standards required may not be implemented. Cause: FRESHFARM Markets, Inc. does not have a process for reviewing its accounting and organizational policies on a regular basis. Effect or potential effect: Costs for purchases subject to the procurement standards could be disallowed if appropriate procedures are not followed. Repeat Finding: No. Recommendation: The Organization should design and implement a procurement policy. This policy should be reviewed annually, or more frequently, if necessary, to ensure any changes in laws and regulations are reflected in internal procedures.