Finding Text
Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 2 subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.