Finding Text
Finding Criteria ? A component of compliance relating to federal awards is maintaining records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition Found ? The Center used federal funds to make purchases greater than $10,000 to $21,900 without obtaining at least three quotes, made purchases greater than $21,900 and did not solicit public bids, and did not document specific circumstances of noncompetitive procurement exceptions. Cause of the Finding ? The Center was under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program (COSTARS) satisfied compliance of quote/bidding requirements of federal purchases. Effect of the Finding ? Failure to follow federal procurement requirements may put the Center at risk of not receiving their full reimbursements or having obligated funds recouped. Questioned Costs ? Purchases made under the false notion that COSTARS satisfies the three quote requirement total $17,052 (4% of ESSER expense), and satisfies the three bid requirement total $24,840 (5% of ESSER expense). Recommendations - Documentation is key for all federal purchases. A purchase price from cooperative purchasing programs can be considered one competitive price proposal and cannot replace a procurement process. Advertise when appropriate, obtain adequate quote/bid information from three vendors, and thoroughly document the ?reason? and ?cost analysis? of sole source noncompetitive procurement exceptions. Management's Response - The Center will follow the policy for quotation/bid requirements for federal purchases and not use cooperative purchasing programs as the only source of quotations/bids for federal purchases. The Center will also improve documentation relating to purchases that meet sole source criteria.