Finding Text
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. The VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements above the micro-purchase threshold. Condition: Procurement documentation for two vendors were not prepared and/or retained to support compliance with the regulations above and the University?s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of twelve vendors with total expenditures greater than the micro-purchase threshold during the fiscal year. For two selections, the University?s VJF documenting and approving the procurement was not prepared. Additionally, one small purchase selection did not include quotes from more than one vendor. Cause: Although the University has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds.