
Public Procurement Change Agents
Public Procurement Change Agents
Back to Basics: Proactive Management of Effective Procurement Audit Files
Dustin discusses procurement audit files as a cornerstone of trust and transparency in procurement, and highlights the core checkpoints for excellence in this area.
Back to basics. Proactive management of effective procurement audit files. For public procurement professionals, a fundamental cornerstone of trust and transparency is to be able to demonstrate that the procurement event was handled professionally. Federal guidelines, which are generally found in the 2 CFR 200 part of the code, set clear expectations for documentation for possible external reviews. And of course, each state and entity may supplement this with their own process and procedure. This article focuses on the core principles that are best practices for all procurement events to drive excellence in this back-to-basics area of our work. So each procurement action should capture the key moments through the process, from solicitation and vendor selection into award and contract formation and ultimately contract administration and closeout. So four key touch points in this area include a pre-solicitation compliance check, documenting that the requirements meet the compliance expectations, which of course may be based on the funding source or the grant conditions, and completing required actions, which for federal dollars can include independent cost estimates, cost justification, and outreach to small, women, minority, and disadvantaged businesses collectively. which is found in the 321B in the 2CFR 200, and it is a precursor for solicitations with federal money. Second, procurement method justification, so what was the rationale for the procurement methods, choosing between sealed bids, RFPs, sole source, etc. Public notice and competition, ensuring the proper posting and advertising of solicitations that meets minimum posting deadlines, document the interested parties and bidders. and ensure that a minimum number of responses are generated to meet competition guidelines. And finally, in solicitation vendor selection, objective proposal evaluation using standardized criteria and scoring rubrics to ensure fairness and defensible outcomes. Moving on into award and contract formation and the documents necessary for our procurement file, award documentation clearly justify the selection decisions, including cost reasonableness, best value determination, and also compliance verifications, looking in SAM for debarment, certification verifications, insurance certificates, etc. Debrief and dispute resolution post the award and maintain records of vendor inquiries and responses to ensure transparency according to internal requirements. Contract term and compliance ensure all agreements align with funding requirements and the solicitation parameters. proper signatures and control, document who approved and executed the contract, contract initiation and notice to proceed, a formal initiation of work and project launch, connecting the teams and establishing escalation procedures. And finally, contract administration and closeout, invoice reviews and payment records, maintain documentation showing that payments align with contract deliverables and rate tables, performance and compliance monitoring, Track vendor adherence to contract terms, deliverables, and key performance indicators. Change orders and modifications. Document all contract amendments, ensuring justification and proper approvals. Then final audit and closeout documentation. Ensure all procurement files contain required records, including the history and correspondence, receipts, and payment logs. By establishing procedure and easy to comply templates in these key areas, procurement organizations will be well equipped to communicate the effectiveness of procurement and to deliver on the public trust.