Finding Text
2022-002?Procurement Federal program information: Funding agency: All Title: All ALN: All Award year and number: All Pass-through entity (if applicable): All Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. According to BRINM?s Purchasing SOP?s, project purchase requests exceeding a value of $25,000 require obtaining three bids. Purchase orders are created for approved project purchase requests and reviewed and signed by the Executive Director or Assistant Director before it can be issued to a vendor. Condition: During fiscal year 2022, BRINM paid a vendor $93,808 for services related to a project. There is no evidence that three bids were obtained for selection of this vendor. Additionally, there was not an approved purchase order for one of the three invoices paid to this vendor. Questioned Costs: None Context: One of 25 nonpayroll transactions tested. Additionally, one of four vendors/subawards tested that were paid over $25,000 during fiscal year 2022. Cause: BRINM?s Grants Manager, who was responsible for all records related to purchasing, accounts payable, and credit cards, resigned in November 2021 without filing many documents. Evidence of bids obtained for use of this vendor could not be located. Effect: Procurement of vendors does not comply with BRINM SOP?s and the procurement requirements identified in 2 CFR Part 200. Auditor?s Recommendations: BRINM should implement its approved SOP?s as referenced above to ensure that purchasing SOP?s are implemented and selection of vendors is adequately documented. Management?s Response: Current Management is not able to confirm nor deny that appropriate documentation was not collected prior to payment but highly doubts that it was not collected based on the reliability of the previous Grants Manager. Management notes that the vendor was specifically mentioned in the Grant submission. Management will ensure that purchasing SOP are implemented and selection of vendors is adequately documented. Management has secured a project management software that will retain project documentation. This should ensure appropriate documentation is collected and available to all Management for the life of the project, until date of destruction.