Audit 370964

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS12856 Award Periods: March 1, 2023 – February 29, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the organization did not maintain appropriate documentation to support the procurement method utilized for contracts selected for testing. Questioned costs: None. Context: Eight (8) of eight (8) procurement transactions selected for testing. Cause: The Organization did not create and maintain appropriate documentation to support the method of procurement utilized. Effect: Possible noncompliance with 2 CFR section 200.320(c)(1) - (3). Repeat finding: No. Recommendation: We recommend the Organization revise its procurement and suspension and debarment policies to be consistent with the Uniform Guidance and consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS12856 Award Periods: March 1, 2023 – February 29, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: As a result of the lack of a suspension and debarment policy, the organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Questioned costs: None. Context: Five (5) of five (5) vendors selected for testing did not have evidence prior to contracting of a check for suspension and debarment. However, subsequent review showed evidence the vendors were not suspended and debarred. Cause: Employee turnover. Effect: Possible noncompliance with 2 CFR section 200.320(c)(1) - (3). Repeat finding: No. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page which includes the date verified. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS12856 Award Periods: March 1, 2023 – February 29, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Recipients of grants from the Bureau of Primary Health Care Health Center Program are required to submit the Uniform Data System (UDS) report on an annual basis. The UDS report contains various information which has been identified as key line items within the compliance supplement for the health center program cluster. Condition: The Organization could not provide documentation to support the amounts tested as key line items within the UDS report. Questioned costs: None. Context: Documentation was not available to support the amounts reported in the UDS report for seven (7) of seven (7) key line items tested. Cause: Employee turnover. Effect: Potential to report inaccurate amounts in the UDS report. Repeat finding: No. Recommendation: We recommend the Organization maintain documentation produced during UDS preparation. Views of responsible officials: There is no disagreement with the audit finding.