Finding Text
Finding Reference: 2023-002 – Procurement Policies and Procedures
Federal Agency: U.S Department of Agriculture
Federal Program: Water and Waste Disposal System for Rural Communities - ALN# 10.760
Compliance Requirement: Procurement, suspension, and debarment
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The Authority does not have any documented procurement procedures. However, during our testing of compliance with procurement guidelines, no further deviations from federal guidelines were noted.
Cause and Effect: The Authority was unacquainted with general procurement standards of the Uniform Grant Guidance. Without documented procurement procedures, it is difficult for the Authority to ensure compliance with relevant compliance requirements.
Questioned Cost: None
Identification of Repeat Finding: No
Recommendation: The Authority should establish documented procedures related to federal procurement.
Views of Responsible Officials: This was first brought to the Authority’s attention in the current year. At such a late date in the federal project that has been in the works for multiple years, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake.