Audit 321617

Finding No. 2023-001: Reporting – Other Matter U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Under the Federal Funding Accountability and Transparency Act (FFATA), all entities receiving federal awards are required to report specific information about the federal funds they receive. Entities must report this information through the Federal Subaward Reporting System (FSRS) or other designated systems. Context The Organization has received multiple federal awards during the year and is subject to FFATA reporting. The noncompliance was identified through a review of the entity's records and evidence of proper submission due to a subrecipient’s lack of Unique Entity Identifier (UEI) number and the Organization’s inability to complete the submission of the FFATA reporting requirement. Cause The Organization’s subrecipient did not have the proper registration information to submit the information related to the FFATA reporting requirements. Effect The failure to report all required FFATA information diminishes the transparency of federal fund usage and prevents the public from having full access to information regarding the stewardship of taxpayer dollars. This noncompliance could potentially affect the Organization’s eligibility for future federal funding. Questioned Costs None Recommendation To ensure compliance with FFATA reporting requirements, we recommend that the Organization train relevant personnel on FFATA requirements and the use of the reporting systems. The Organization should also establish a monitoring system to verify that all subrecipients are evaluated for proper registration for the Organization to satisfy all necessary reporting requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2023-002: Procurement – Significant Deficiency in Internal Control Over Compliance U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Federal award recipients must comply with procurement standards as outlined in the Uniform Guidance which requires recipients to conduct procurements in a manner that provides full and open competition. Exceptions to this requirement, such as sole-source procurements, must be adequately justified and documented in accordance with federal regulations. Context The Organization received a federal award which included funding for specialized services. Certain vendors were chosen as the sole-source providers for these services. However, as an exception to the Organization’s procurement policy, there was no written justification as to why no other vendors were considered or how these vendors were uniquely qualified to meet the project’s needs. Upon inquiry of management, there was supported justification for the selection of these vendors which provided a reasonable basis, but there was nothing formally maintained to support this selection. Cause The finding suggests a gap in the Organization's procurement policies and procedures, which failed to ensure that proper documentation for sole-source justifications be retained. Effect The lack of adequate documentation for sole-source procurements raises concerns regarding the propriety of the procurement process and whether the organization obtained the best value for the federal funds expended. This deficiency could potentially result in questioned costs and might impact the Organization's eligibility for future federal funding. Questioned Costs None Recommendation We recommend that the Organization take the following actions to address this significant deficiency through review and reinforce training on federal procurement requirements for all staff involved in the procurement process: (1) Updating procurement policies and procedures to require documentation of sole-source justifications, including evidence of the unique qualifications of the vendor and the specific rationale for not considering other potential vendors; (2) Conducting a retrospective analysis of the procurement in question to determine if there were other qualified vendors that could have been considered; and (3) Developing and implementing a corrective action plan to ensure all future sole-source procurements are fully documented and comply with federal requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2023-001: Reporting – Other Matter U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Under the Federal Funding Accountability and Transparency Act (FFATA), all entities receiving federal awards are required to report specific information about the federal funds they receive. Entities must report this information through the Federal Subaward Reporting System (FSRS) or other designated systems. Context The Organization has received multiple federal awards during the year and is subject to FFATA reporting. The noncompliance was identified through a review of the entity's records and evidence of proper submission due to a subrecipient’s lack of Unique Entity Identifier (UEI) number and the Organization’s inability to complete the submission of the FFATA reporting requirement. Cause The Organization’s subrecipient did not have the proper registration information to submit the information related to the FFATA reporting requirements. Effect The failure to report all required FFATA information diminishes the transparency of federal fund usage and prevents the public from having full access to information regarding the stewardship of taxpayer dollars. This noncompliance could potentially affect the Organization’s eligibility for future federal funding. Questioned Costs None Recommendation To ensure compliance with FFATA reporting requirements, we recommend that the Organization train relevant personnel on FFATA requirements and the use of the reporting systems. The Organization should also establish a monitoring system to verify that all subrecipients are evaluated for proper registration for the Organization to satisfy all necessary reporting requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2023-002: Procurement – Significant Deficiency in Internal Control Over Compliance U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Federal award recipients must comply with procurement standards as outlined in the Uniform Guidance which requires recipients to conduct procurements in a manner that provides full and open competition. Exceptions to this requirement, such as sole-source procurements, must be adequately justified and documented in accordance with federal regulations. Context The Organization received a federal award which included funding for specialized services. Certain vendors were chosen as the sole-source providers for these services. However, as an exception to the Organization’s procurement policy, there was no written justification as to why no other vendors were considered or how these vendors were uniquely qualified to meet the project’s needs. Upon inquiry of management, there was supported justification for the selection of these vendors which provided a reasonable basis, but there was nothing formally maintained to support this selection. Cause The finding suggests a gap in the Organization's procurement policies and procedures, which failed to ensure that proper documentation for sole-source justifications be retained. Effect The lack of adequate documentation for sole-source procurements raises concerns regarding the propriety of the procurement process and whether the organization obtained the best value for the federal funds expended. This deficiency could potentially result in questioned costs and might impact the Organization's eligibility for future federal funding. Questioned Costs None Recommendation We recommend that the Organization take the following actions to address this significant deficiency through review and reinforce training on federal procurement requirements for all staff involved in the procurement process: (1) Updating procurement policies and procedures to require documentation of sole-source justifications, including evidence of the unique qualifications of the vendor and the specific rationale for not considering other potential vendors; (2) Conducting a retrospective analysis of the procurement in question to determine if there were other qualified vendors that could have been considered; and (3) Developing and implementing a corrective action plan to ensure all future sole-source procurements are fully documented and comply with federal requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.