Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS02457-18; H80CS02457-19 Award Periods: February 1, 2021 ? January 31, 2022; February 1, 2022 ? January 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The organization had assessed two patients with a larger sliding fee discount than for which they were eligible based on their family size and income documentation. Questioned Costs: None. Context: Two (2) of Forty (40) transactions selected for testing. Cause: One patient did not have a current sliding fee assessment of family size and income and one patient was assigned a higher discount under an alternative sliding fee scale that allowed for a sliding fee discount up to 250% of the federal poverty guidelines, but which was ultimately rescinded and replaced with a sliding fee scale that does not exceed 200% of the federal poverty guidelines. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.