Finding Text
Condition: During our Procurement, Suspension and Debarment test, we found 4 instances out a sample of 51 with respect to 84.425F funds and 2 cases with respect to 84.431S on which the proper purchase method was not used by the Institution. Criteria: As per regulation, 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 200.320 which requires recipients to Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). Cause: The Institution followed the small purchase method for these disbursements because there are very few available providers in the island that can deliver the services required and they requested quotes from all known providers, but did not followed the seal bid, competitive proposal or non-competitive proposal (if properly documented) as required by regulations. Effect: Not following established controls could result in non-compliance of federal regulations for the program. Questioned costs: -0- Since the Institution requested quotes from all know providers no cost are questioned for this finding. Recommendation: Procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.