Finding Text
Finding 2023-001: Procurement
Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518
Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement
procedures consistent with the requirements for procurement regulations included in paragraphs 318
through 327.
Condition: During our audit, we noted multiple instances where vendors were engaged without a
complete set of documentation supporting a procurement process, or justification to support using a
noncompetitive procurement process in accordance with CFR 200.320(c).
Cause: Asylum Access does not maintain documented policies regarding procurement and therefore
compliance with Federal regulations cannot be determined.
Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into
contracts for goods or services under Federal awards that were not adequately procured based on the
regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the
costs paid for the goods or services.
Effect: Asylum Access may have disallowed costs for not properly procuring goods or services.
Questioned Costs: None noted.
Identification as a Repeat Finding: N/A
Recommendation: We recommend Asylum Access establish a procurement policy to become
compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to
the new policy to ensure compliance.