Finding Text
Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policy in effect for the year under audit, it was noted that policy did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. In addition, the District did not maintain documentation of the selection of vendors in compliance with Uniform Guidance for the five (5) small purchase transaction selected for testing, as part of a statistically valid sample. Questioned costs: N/A Context: The District's purchasing policy was adopted several years ago and the formal policy has not be updated for the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. For the 5 vendors selected for testing in a non-statistically valid sample, the District was not able to provide documentation of their compliance with the required vendor selection criteria. Cause: The District did not review and update the procurement policy in effect to comply with Uniform Guidance and update threshold identified in the most current updates to the Uniform Guidance. Effect: The District's purchasing policy in effect during the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procumbent methods, micro purchase and small purchase transactions. In addition, the District may not apply proper procurement requirements to transactions. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Views of responsible officials: There is no disagreement with the audit finding.