Finding Text
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.