Audit 22223

Finding 2022-001 - Procurement Federal Agency: U.S. Department of Health and Human Services Passed through City of Boston Commission on Affairs of the Elderly Federal Program Title: National Family Caregiver Support, Title III, Part E Assistance Listing Number: 93.052 Type of Finding: Material Instance of Noncompliance and Significant Deficiency in Internal Controls over Compliance. Criteria: BSHC is required to maintain policies and procedures over the procurement of goods and services with Federal funds in accordance with 2 CFR Part 200.318 through 200.327. Additionally, the City of Boston requires Title III grantees to comply with the Boston Age Strong Commission?s contract manual, which contains specific procurement requirements. Condition: During our testing of 22 purchases charged to Title III funds, we noted that BSHC did not have supporting documentation or evidence that the Federal and City of Boston procurement procedures were followed. Cause: Fiscal year 2022 was the first year BSHC was subject to a Federal Uniform Guidance audit. Accordingly, management had not instituted separate procurement procedures over Federal and non-Federal procurements. All purchases were subject to BSHC?s general procurement/purchasing procedures. Effect: BSHC procured goods and services using Federal funds under their internal policy that was not in full compliance with the requirements set forth by the Uniform Guidance which could affect future Title III funding. Questioned Costs: None Recommendation: BSHC should implement a formal, Board approved, procurement policy and procedures which encompass the requirements in Federal CFR Part 200.318 through 200.327 and the Boston Age Strong Commission contract manual requirements. These procedures should be applied to any purchases made with Federal funds. In addition, BSHC should review its vendor files to ensure that appropriate procurement documentation exists throughout. Repeated finding: No Management?s Response: Management is in agreement with the recommendation. Subsequent to the Board review of the fiscal year 2022 audit package, Boston Senior Home Care?s procurement policy will be revised to align with Federal guidelines. The policy will go to the Audit Committee or full Board for approval.

Finding 2022-001 - Procurement Federal Agency: U.S. Department of Health and Human Services Passed through City of Boston Commission on Affairs of the Elderly Federal Program Title: National Family Caregiver Support, Title III, Part E Assistance Listing Number: 93.052 Type of Finding: Material Instance of Noncompliance and Significant Deficiency in Internal Controls over Compliance. Criteria: BSHC is required to maintain policies and procedures over the procurement of goods and services with Federal funds in accordance with 2 CFR Part 200.318 through 200.327. Additionally, the City of Boston requires Title III grantees to comply with the Boston Age Strong Commission?s contract manual, which contains specific procurement requirements. Condition: During our testing of 22 purchases charged to Title III funds, we noted that BSHC did not have supporting documentation or evidence that the Federal and City of Boston procurement procedures were followed. Cause: Fiscal year 2022 was the first year BSHC was subject to a Federal Uniform Guidance audit. Accordingly, management had not instituted separate procurement procedures over Federal and non-Federal procurements. All purchases were subject to BSHC?s general procurement/purchasing procedures. Effect: BSHC procured goods and services using Federal funds under their internal policy that was not in full compliance with the requirements set forth by the Uniform Guidance which could affect future Title III funding. Questioned Costs: None Recommendation: BSHC should implement a formal, Board approved, procurement policy and procedures which encompass the requirements in Federal CFR Part 200.318 through 200.327 and the Boston Age Strong Commission contract manual requirements. These procedures should be applied to any purchases made with Federal funds. In addition, BSHC should review its vendor files to ensure that appropriate procurement documentation exists throughout. Repeated finding: No Management?s Response: Management is in agreement with the recommendation. Subsequent to the Board review of the fiscal year 2022 audit package, Boston Senior Home Care?s procurement policy will be revised to align with Federal guidelines. The policy will go to the Audit Committee or full Board for approval.