TOWN OF WINSLOW

2019-002 ? Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the School Department is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the new procurement standards, the School Department is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the School Department does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The School Department has not adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards that are not currently addressed in the School Department?s procurement policy are as follows: ? Conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts ? Contracting with small and minority businesses, women?s business enterprises, and labor surplus area firms ? Bonding requirements ? Contract provisions ? Subrecipient and contractor determinations ? Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the School Department?s procurement policy appropriately. This would include adding any missing components to the School Department?s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards. Management response/corrective action plan: The School Department is working on implementing a procurement policy to be in line with federal procurement standards in 2020.