Finding Text
Condition:
The Organization does not have a documented procurement policy that conforms to applicable federal statutes and
the procurement requirements identified in 2 CFR Part 200.
Context:
During the year, the Organization made a purchase of property that was greater than the Simple Acquisition
Threshold of $250,000. As part of the audit procedures, we requested the Organization’s documented procurement
policy. The Organization did not have a documented procurement policy. Prior to making purchases in excess of the
simplified acquisition threshold, the Organization performed a price analysis in a manner consistent with 2 CFR Part
200.
Cause:
The Organization was not aware that a documented procurement policy was required.
Criteria:
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must
follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own
documented procurement procedures, which reflect applicable state and local laws and regulations, provided that
the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part
200.
Effect:
Without documented procurement policies, the Organization could procure assets in a manner that is not consistent
with 2 CFR Part 200.
Recommendation:
We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318
through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and
procurement requirements.
Management’s Response:
Management agrees.