Finding Text
Criteria: an entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must confirm to the procurement standards identified in CFR § 200.317 through 200.327. Condition: The Center maintans specific grant manuals and guidelines as its written policies; however, they have inconsistently or inadequately been using those manuals and guidelines. The Center made two large purchases under the Head Start grant exceeding micro-purchase thresholds without obtaining price or rate quotations from an adequate number of qualified sources. Cause: Thresholds are often considered based on unit price instead of the aggregate purchase amount based on certain grantor requirements to obtain written approval for purchases based on unit price. In addition, procedures are considered unnecessary by management for purchases falling within the grantor approved budget amounts. Effect: Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed or subject the entity to possible claims. It was determined that the items procured were reasonable in costs with other vendors. Recommendation: We recommend management assess and adhere to the internally developed policy for all procurements using Federally sourced funds.