Finding 8214 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-01-10
Audit: 10829
Organization: Institute for Wildlife Studies (CA)

AI Summary

  • Core Issue: Lack of proper documentation in procurement files, violating Uniform Guidance section 200.318.
  • Impacted Requirements: Failure to maintain records detailing procurement history, including rationale and contractor selection.
  • Recommended Follow-Up: Review procurement policies with staff and ensure compliance with documentation requirements to prevent repeat findings.

Finding Text

Federal agency: U.S Department of Defense Federal program title: Conservation and Rehabilitation of Natural Resources on Military Installations ALN Number: 12.005 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: Uniform Guidance section 200.318 states non-Federal entities must maintain records sufficient to detail the history of procurements. 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: For the one purchase selected for testing, we noted written documentation on the selection method was not retained in the procurement file. We also noted that one item selected for suspension and debarment did not have proper documentation. Context: One out of two items selected for testing of procurement and one out of one item selected for testing of suspension and debarment did not have proper documentation. Cause: Written support was not retained in the procurement file at the time of the procurement. Effect: Procuring vendors without full and open competition. Repeat Finding: See prior year finding 2021-002 Recommendation: Auditor recommends the Institute review the various procurement requirements with the individuals involved in this process to ensure they understand the requirements. It is also recommended to review the policies and procedures around procurement to ensure key individuals are following them. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Institute has recently updated the purchasing policies and is reviewing process changes in order to ensure appropriate documentation is maintained for purchasing related to Federal programs.

Corrective Action Plan

Recommendation: Auditor recommends the Organization review the various requirements involved with procurement requirements with the individuals involved in this process to ensure they understand the requirements. It is also recommended to review the policies and procedures around procurement to ensure key individuals are following them. Explanation of disagreement with audit finding There is no disagreement with the audit finding. Action taken in response to finding We will annually review the IWS Procurement Policy with personnel authorized to make Small Purchases (between $10,000 and $250,000 per transaction) and/or Large Purchases (over $250,000 per transaction). This review will take place during the first two weeks of January each year. In addition, the IWS Bookkeeper and/or the IWS will alert the Operations Manager of any purchases that exceed $10,000. The Operations Manager will contact the employee who made or authorized the purchase to ensure that the proper procedures were followed in preparation for the purchase. Name(s) of the contact person(s) responsible for corrective action Operations Manager Dick Johnson, Bookkeeper Nancy Stufflebeam, and Operations Analyst Robin Smukler Planned completion date for corrective action plan Other than the annual review of the Procurement Policy, these procedures are currently in place. The initial annual review will take place during the first two weeks of 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 584656 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
12.005 Conservation and Rehabilitation of Natural Resources on Military Installations (b) $2.11M
15.945 Cooperative Research and Training Programs Ð Resources of the National Park System $272,390
15.247 Wildlife Resource Management $56,119
15.611 Wildlife Restoration and Basic Hunter Education $37,547
15.657 Endangered Species Conservation Ð Recovery Implementation Funds $27,372
15.248 National Landscape Conservation System (b) $23,461