Core Issue: Astraea's procurement policy lacks clear procedures for compliance with federal regulations, leading to potential noncompliance.
Impacted Requirements: CFR 200.318-327 mandates documented procurement procedures, which Astraea has not fully implemented.
Recommended Follow-Up: Update the procurement policy to align with CFR 200 and train staff on the new procedures to ensure compliance.
Finding Text
Finding 2022-005: Procurement
Information on the Federal Programs: Assistance Listing Number 98.001
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: Astraea's procurement policy references CFR 200.318-327 however the policy does not note how it will comply with the requirements and what the process is to ensure compliance is achieved. During our audit we noted multiple instances where vendors were engaged without any documentation of procurement process or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c).
Cause: Astraea does not have a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations.
Context: Without updating the policy to comply with CFR 200, Astraea 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 or pass-through entity could disallow the costs paid for the goods or services.
Effect: Astraea may have disallowed costs for not properly procuring goods or services.
Questioned Costs: None noted.
Identification as a Repeat Finding: Yes - 2021-006.
Recommendation: We recommend Astraea update the procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.