Special Olympics Massachusetts, Inc.

Finding No. 2024-002 – Lack of a Formal Procurement Policy Federal award agency: U.S. Department of Education Pass-through granting agency: Special Olympics, Inc. Program name and ALN: Special Education – Special Olympics Education Programs – 84.380W Federal award identification number: Y16 23 800 20, Y16 24 800 19 Federal award year: September 1, 2023 – June 30, 2024 and September 1, 2024 – June 30, 2025 Criteria: According to the Uniform Guidance (2 CFR 200), non-federal entities receiving federal awards for which procurement is a required compliance area, must use documented procurement procedures that are consistent with applicable federal standards, to ensure full and open competition and compliance with federal procurement requirements. Condition: While the entity reviews vendors used for reasonableness and fair competition, the entity does not have a formal, written procurement policy in place. Questioned Costs: None. Cause: Management has not established or formally documented procurement policies and procedures that align with Uniform Guidance requirements. This appears to be due to a lack of awareness of the specific federal procurement documentation requirements applicable to the program. Effect: Without a formal procurement policy, the entity may not consistently comply with federal procurement requirements, including competition, cost or price analysis, and conflict-of-interest provisions. The absence of documented procedures prevents the auditor from determining whether procurement transactions were conducted in accordance with Uniform Guidance, increasing the risk of noncompliance. Recommendation: We recommend that management develop, formally document, and implement a procurement policy that complies with the Uniform Guidance. The policy should address, at a minimum, procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and approval thresholds. Management should also ensure that the policy is consistently applied to all federally funded procurements and retained as support for future audits. Views of responsible officials and planned corrective actions: Management agrees with the finding, and plans to create a formal procurement policy that complies with the Uniform Guidance.

In 2024, Special Olympics Massachusetts relied on nationally approved vendors for procurement of education materials, awards and specialty items. These nationally approved vendors provide affiliated programs discounted rates based on the bulk item purchase of programs. In 2025, some of those nationally affiliated programs were discontinued and Special Olympics MA did seek multiple bids for items such as awards and materials. Moving forward, CFO Clinton Rowe will develop and implement a written procurement policy that meets the requirements of the Uniform Guidance by June 30, 2026.