COMPUTER SCIENCE TEACHERS ASSOCIATION

FINDING 2021-002 ? PROCUREMENT POLICY CFDA NUMBER: 84.411C PROGRAM TITLE: Education Innovation and Research (EIR) Program - Early-Phase Grants DEPARTMENT: U.S. Department of Education AWARD YEAR: 2021 Criteria: Per 2 CFR section 200.318, non-Federal entities must have and use documented procurement procedures, consistent with State, Local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR sections 200.317 through 200.327. Condition: The Organization does not have a formal procurement policy in place that includes the essential elements as outlined in 2 CFR sections 200.317 through 200.327 setforth within the Uniform Guidance. Questioned Costs: None Context: There was an absence of a formal procurement policy that contained Uniform Guidance elements outlined in 2 CFR sections 200.317 through 200.327. Cause: The Organization was unaware of the Uniform Guidance requirements for procurement and written policies and procedures. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance with other Federal programs as it relates to Federal procurement. Recommendation: The Organization should adopt a formal procurement policy to be in line with current Uniform Guidance Standards set forth in 2 CFR sections 200.317 through 200.327. Management's Response: Management agrees with this finding. See Corrective Action Plan.

2021-002 Education Innovation and Research (EIR) Program ? Early-Phase Grants, CFDA No. 84.411C Recommendation: The auditors recommend the Organization adopt a formal procurement policy to be in line with current Uniform Guidance Standards set forth in 2 CFR sections 200.317 through 200.327. Actions Taken or Planned: CSTA has implemented a procurement policy that is aligned with current Uniform Guidance Standards set forth in 2 CFR sections 200.317 through 200.327. This policy was reviewed by a third-party contractor with expertise in grant policies and procedures. The procurement policy has been in place as of November 2021. Person Responsible: Jake Baskin, Executive Director Estimated Date of Completion: December 2021