Acquisition Management: Smithsonian Did Not Consistently Comply with Spending and Reporting Requirements for CARES Act Funds

Submitting OIG:

Smithsonian Institution OIG

Date Issued:

Friday, February 23, 2024

Agency Reviewed / Investigated:

Smithsonian Institution

Submitting OIG-Specific Report Number:

OIG-A-24-05

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

$28,999

Funds for Better Use:

Number of Recommendations:

Report updated under NDAA 5274:

View Document:

Attachment	Size
OIG-24-05.pdf	1.18 MB

Recommendation Number	Recommendation Status	Significant Recommendation
OIG-A-24-05-01	Open	Yes
Assess whether emergency purchase cards can be used for sole-source purchases over $10,000. If so, OCon&PPM should update the purchase card’s policies and procedures to allow sole-source purchasing and ensure that relevant emergency purchase card personnel are familiar with the purchasing and documentation requirements for emergency purchase cards.
OIG-A-24-05-02	Open	Yes
Update PCPM Part 2 - Simplified Acquisitions to clarify that each unit needs to designate personnel responsible for entering data into FPDS.
OIG-A-24-05-03	Open	Yes
Create and maintain a list of personnel responsible for entering data into FPDS to facilitate communication of future emergency spending guidance and verify compliance with FPDS training requirements.
OIG-A-24-05-04	Open	Yes
Establish and implement procedures to monitor the quality of sole-source procurement justifications.
OIG-A-24-05-05	Open	Yes
In coordination with OCon&PPM, distribute guidance that includes examples of the information required to support sole-source justifications for purchase orders, and provide training to Smithsonian Facility employees who participate in sole-source purchasing on the applicable policies and procedures for sole-source purchases.
OIG-A-24-05-06	Open	Yes
Establish processes that ensure the completeness and appropriate accessibility of documentation for purchase orders and purchase card transactions. The process should include periodic monitoring of the files to ensure compliance with the Procurement and Contracting Procedures Manual and the Purchase Card Program’s Desk Reference.
OIG-A-24-05-07	Open	Yes
Update Emergency Declaration procedures to address who has the authority to grant exceptions to policies and also to provide general guidance as to how these exceptions are to be communicated and documented.
OIG-A-24-05-08	Open	Yes
Develop procedures that identify internal controls to ensure that only eligible expenses are funded through emergency appropriations, if these situations arise in the future.
OIG-A-24-05-09	Open	Yes
Assign responsibility over monitoring the accuracy and completeness of FPDS data.
OIG-A-24-05-10	Open	Yes
Establish processes that ensure the completeness and appropriate accessibility of documentation for purchase orders and purchase card transactions. The process should include periodic monitoring of the files to ensure compliance with the Procurement and Contracting Procedures Manual and the Purchase Card Program’s Desk Reference.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

OIG-A-24-05-01

Open

Yes

Assess whether emergency purchase cards can be used for sole-source purchases over $10,000. If so, OCon&PPM should update the purchase card’s policies and procedures to allow sole-source purchasing and ensure that relevant emergency purchase card personnel are familiar with the purchasing and documentation requirements for emergency purchase cards.

OIG-A-24-05-02

Open

Yes

Update PCPM Part 2 - Simplified Acquisitions to clarify that each unit needs to designate personnel responsible for entering data into FPDS.