Finding Text
Finding 2023-002: Procurement
Information of the Federal Program: Assistance Listing Number 19.345
Criteria: CFR 200.318 states that non-Federal entities must have and use documented
procurement procedures consistent with the requirements for procurement regulations included in
paragraphs 318 through 327.
Condition: The Organization did not provide supporting documentation for certain procurement
decisions, and we noted instances where a memo was used to justify noncompetitive procurement
when it was not clearly justified by one of the reasons permitted within CFR 200.320:
The acquisition of property or services, the aggregate dollar amount of which does not exceed
the micro-purchase threshold;
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from
publicizing a competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive
procurement in response to a written request from the non-Federal entity;
After solicitation of a number of sources, competition is determined inadequate.
Cause: The Organization has a procedure in place to ensure all vendors or suppliers paid with
Federal funding are engaged in compliance with the Federal regulations but compliance with the
policy was not always documented.
Effect or Potential Effect: The Organization may have disallowed costs for not properly procuring
goods or services. Questioned Costs: None noted
Context: The Organization is at risk of entering into contracts for goods or services under Federal
awards that were not adequately procured based on the regulations in the Uniform Guidance and
the awarding agency could disallow the costs paid for the goods or services.
Identification as a Repeat Finding, if Applicable: N/A
Recommendation: We recommend that the Organization update its policies and procedures to
ensure compliance with CFR 200.320 regarding noncompetitive procurement. In addition, we
recommend that documentation be maintained for all procurement decisions in accordance with
established policy.