Finding Text
The U. S. Code of Federal Regulations Title 2, Part 200.320, of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform
Guidance) states that non-Federal entities must have and use documented procurement
procedures. If purchases are made that fall within the small purchase thresholds defined in the
Uniform Guidance, price or rate quotations much be obtained from an adequate number of
qualified sources. Board Policy 3.20.5 states that procurement transactions for federal programs
that are not subject to the state procurement laws but exceed the aggregate amount of the federal
micro-purchase threshold, will be obtained by utilizing price or rate quotes from two or more
qualified sources. The Lawrence County Board of Education (the “Board”) entered into a
contract for mobile STEM classroom services totaling $96,660.00 that was within the Uniform
Guidance small purchase threshold without obtaining price or rate quotations. The Board did not
follow their procurement policies or the Uniform Guidance regarding this purchase. As a result,
the Board did not comply with the Uniform Guidance procurement requirements. Recommendation:
The Board should comply with the U. S. Code of Federal Regulations Title 2, Part 200.320 of the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance) when entering into contracts that are within the small purchase
threshold.