Primo Center for Women and ChildrenNon-Profit

Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). Condition: The Organization's policies and procedures do not have an internal control in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. Cause: The Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds. Recommendation: We recommend that the Organization update its procurement policy to specifically address and provide for the necessary controls to ensure that vendors and others in a covered transaction are verified that the entity is nor suspended or debarred. In additional, the policy should include details about maintaining evidence of actions taken to ensure proper suspension and debarment requirements are met. Views of Responsible Officials: Management agrees with the finding and recommendation.

Criteria: The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The Organization did not maintain sufficient documentation of its procurement decisions. Cause: The exception noted above was due a lack of documentation of the process followed by the Organization to ensure that all procurements of goods and services are in accordance with the Uniform Guidance and it’s procurement policy. Context: The population subject procurement requirements was one vendor under the small purchase threshold. The Organization did not maintain documentation of quotes from other qualified sources and document the selection of the vendor. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Recommendation: The Organization should ensure its procedures specifically include maintaining documentation of procurement decisions. Views of Responsible Officials: Management agrees with the finding and recommendation.

GSA_MIGRATION