Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200.
Condition/Context
The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance.
Questioned Costs
$0
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200.
Condition/Context
The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance.
Questioned Costs
$0
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Significant deficiency in internal controls and noncompliance with the reporting requirements.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
In accordance with 2 CFR Part 170, recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS as required by appendix A to Part 2 CFR part 170.
Condition/Context
During reporting compliance testing for the year ended June 30, 2024, for one of one subaward made the Organization did not report the subaward made greater than $30,000 in FSRS.
Cause
The Organization did not have internal controls in place to ensure that all subawards made greater than $30,000 were included in FSRS.
Effect
First tier subawards of greater than $30,000 were not reported in FSRS.
Questioned Costs
Not applicable
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Significant deficiency in internal controls and noncompliance with the reporting requirements.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
In accordance with 2 CFR Part 170, recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS as required by appendix A to Part 2 CFR part 170.
Condition/Context
During reporting compliance testing for the year ended June 30, 2024, for one of one subaward made the Organization did not report the subaward made greater than $30,000 in FSRS.
Cause
The Organization did not have internal controls in place to ensure that all subawards made greater than $30,000 were included in FSRS.
Effect
First tier subawards of greater than $30,000 were not reported in FSRS.
Questioned Costs
Not applicable
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200.
Condition/Context
The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance.
Questioned Costs
$0
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200.
Condition/Context
The Organization has not enacted a procurement policy which meets the requirements of CFR 200.317 through 200.327. As a result, the Organization could not produce documentation of the history of the procurement, including justification of the procurement method and performance of a suspension and debarment search. The Organizations major program had a single vendor in which the aggregate purchases as part of the contract was greater than the micro-purchase threshold. The Organization determined at the time of procurement that due to the specialized nature of on-site medical professional services being procured that the contract could only be fulfilled by a single source.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy met the requirement of the Uniform Guidance.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement and did not meet the requirement of the Uniform Guidance.
Questioned Costs
$0
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Significant deficiency in internal controls and noncompliance with the reporting requirements.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
In accordance with 2 CFR Part 170, recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS as required by appendix A to Part 2 CFR part 170.
Condition/Context
During reporting compliance testing for the year ended June 30, 2024, for one of one subaward made the Organization did not report the subaward made greater than $30,000 in FSRS.
Cause
The Organization did not have internal controls in place to ensure that all subawards made greater than $30,000 were included in FSRS.
Effect
First tier subawards of greater than $30,000 were not reported in FSRS.
Questioned Costs
Not applicable
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Significant deficiency in internal controls and noncompliance with the reporting requirements.
Federal Agency: Department of Health and Human Services
Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance
Assistance Listing Number: 93.732
Award Numbers and Years: All awards
Criteria
In accordance with 2 CFR Part 170, recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS as required by appendix A to Part 2 CFR part 170.
Condition/Context
During reporting compliance testing for the year ended June 30, 2024, for one of one subaward made the Organization did not report the subaward made greater than $30,000 in FSRS.
Cause
The Organization did not have internal controls in place to ensure that all subawards made greater than $30,000 were included in FSRS.
Effect
First tier subawards of greater than $30,000 were not reported in FSRS.
Questioned Costs
Not applicable
Repeat Finding
Not a repeat finding.
Recommendation
We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.