Finding Text
Finding 2022-002: Procurement
Information on the Federal Program: 93.471
Criteria or Specific Requirement: CFR 200.320 specifies methods of procurement that must be used
including competitive bidding where applicable, and limits the use of procurement by noncompetitive
proposals to specific instances or situations including 1) the item is available only from a single source,
2) The public exigency or emergency for the requirement will not permit a delay resulting from
competitive solicitation, 3) the Federal awarding agency or pass-through entity expressly authorizes
noncompetitive proposals in response to a written request from the non-Federal entity, or 4) after
solicitation of a number of sources, competition is determined inadequate.
Condition: The Organization revisited their procurement policy following the completion of the fiscal
year 2021 audit. As a result of the timing, vendors were hired prior to the integration of the updated
procurement procedures and we noted instances where contractors were engaged in excess of the
$10,000 procurement threshold, but adequate competitive bidding support was available.
Cause: The Organization has not performed procedures in accordance with its procurement policies
for certain purchases.
Effect or Potential Effect: If procurement procedures are not followed, there is a risk that the
Organization will not perform a proper evaluation of each element of cost to determine
reasonableness.
Questioned Costs: Undetermined
Context: Our testwork consisted of statistical sampling as well as substantive testwork over various
samples of expenditures, and were determined to be representative of the population for the fiscal year
under audit.
Identification as a Repeat Finding, if Applicable: See prior year finding 2021-005. Recommendation: We recommend that the Organization adhere to the current procurement
guidelines, and also recommend that the Organization establish a form to document the procurement
process, including bids received, conclusion, individuals involved and date.