Finding 976303 (2023-001)

Procurement Policy Federal Agency: U.S. Department of the Treasury Federal Program Title: NeighborWorks® America Grant Cluster Federal Assistance Listing Number: 21.U12 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or Specific Requirement: The Organization should have a formal procurement policy to guide the Organization when entering into covered transactions. The policy needs to include all components identified in 2 CFR 200.318. Condition: The Organization had 3 expenses applied to the grant in excess of the $10,000 required micro-purchase threshold and below their internal $15,000 policy. The Organization also did not have a procurement policy in place that follows Uniform Guidance. Questioned Costs: None Context: The Organization had an internal procurement policy in effect that specified procurement controls and documentation for purchases greater than $15,000, which exceeds the $10,000 micro-purchase threshold required under Uniform Guidance. The Organization entered into three transactions below their $15,000 internal policy but in excess of the $10,000 required micro purchase threshold for which an adequate number of price or rate quotes were not documented. Cause: Management Oversight Effect: The effect of not having a procurement policy with all the required components would be noncompliance with 2 CFR 200.318. Recommendation: It is recommended that the Organization review and update the procurement policy as necessary to ensure compliance with the Uniform Guidance. Views of Responsible Officials: There is no disagreement with the audit finding. Refer to the Organization’s Corrective Action Plan for more information.