Criteria: In accordance with CFR 200.318(i), the non-federal entity must maintain 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. In addition, in accordance with CFR 200.318(a) the nonfederal entity must have and use documented procurement procedures consistent with federal procurement standards. Condition: Expenditures tested that met the small purchase threshold (purchases with a cost between
$10,000 and $250,000) did not have documentation detailing the history of procurement. Cause: The School does not have procurement policies that follow federal guidelines, specifically 2 CFR 200.320 Methods of procurement to be followed. Effect: Property and equipment additions made using federal funds during the year did not have appropriate a support showing procurement policies were followed. Questioned costs: $83,864 Context: Two out of two purchases tested for procurement did not follow federal procurement methods. Recommendation: We recommend that the School institute procurement policies whereby acquisitions follow appropriate procurement steps as required by 2 CRF 200.350 and documentation of procurement decisions is maintained. Action Plan:
The School will develop a Procurement Policy that follows the formal bid process and ensures that the school is able to acquire goods based on the most advantageous balance of price, quality, and performance. The School will maintain procurement decision records in vendor files. Person Responsible: Yvonne Bullock, CEO/Head of School Policies are approved by the Board of Directors