Core Issue: The Alliance lacks a formal procurement policy, which is required for compliance with federal guidelines.
Impacted Requirements: This finding relates to 2 CFR Part 200, which mandates adherence to procurement provisions for federal awards.
Recommended Follow-Up: The Alliance should create a procurement policy by the end of 2023, potentially seeking external assistance if needed.
Finding Text
Procurement
Federal agency: Department of Health and Human Services
Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition
Assistance Listing Number: 93.591
Award years: 2021 and 2022
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with procurement provisions. The Alliance should have a policy in place to ensure compliance with procurement provisions.
Condition: The Alliance does not have a procurement policy.
Questioned costs: None.
Context: The island of American Samoa has limited options for procuring goods and services compared to what is available on the mainland.
Cause: The Alliance was unaware of the requirements for a procurement policy.
Effect: A failure to meet the minimum requirements for procurement in conformity with Uniform Guidance may result in noncompliance and questioned costs.
Repeat Finding: No
Recommendation: We recommend the Alliance develop a procurement policy that aligns with the requirements of Uniform Guidance. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy.
Views of Responsible Officials: Management agrees. A procurement policy will be developed and added to the finance polices and procedures before end of 2023.
Corrective Action Plan
Recommendation: We recommend the Alliance develop a procurement policy that aligns with the requirements of Uniform Guidance. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy.
Views of Responsible Officials: Management agrees. A procurement policy will be developed and added to the finance polices and procedures before end of 2023.
Categories
Procurement, Suspension & DebarmentAllowable Costs / Cost PrinciplesMaterial WeaknessInternal Control / Segregation of DutiesSpecial Tests & Provisions