Finding Text
#2022-001 ? Uniform Guidance Procurement Standards Criteria: In accordance with 2 CFR sections 200.318 through 200.326 of the Uniform Guidance, Amistad, Inc. is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Condition: The OMB revised regulations applicable to federally funded programs are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the Organization has no formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Questioned Costs: None Context: The Organization has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not note any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards are not currently addressed in an official, written procurement policy. Cause: Staff turnover and management oversight. Repeat Finding: Yes Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and develop an appropriate written procurement policy. This would include incorporating definitions of the types of procurement (i.e. micro-purchases, small purchases, and small acquisition threshold) to match the language used in the Uniform Guidance procurement standards.