Audit 399166

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 C16CS50476-01-03 Program Year 2025 Criteria or Specific Requirement – Procurement, Suspension, & Debarment – 2 CFR 200.320 and 2 CFR 180. Condition – The Organization completed purchases exceeding the small purchase threshold for which bid solicitation, evaluation, and selection documents were not completed. The Organization’s Procurement Policy does not explicitly identify all purchase types included in 2 CFR 200.320 and 2 CFR 180. Cause – The Procurement Policy is not consistent with Federal regulations and was not properly applied during the year. Effect or Potential Effect – Purchases were made without adhering to Federal procurement requirements. Questioned Costs – Unknown. Context – A sample of two purchases were tested from a population of eleven transactions subject to procurement requirements, representing $606,467 in federal expenditures. The sample was not, and is not intended to be, statistically valid. Of the two purchases tested, neither transaction, totaling $211,018, was documented in accordance with Federal procurement requirements. Identification as a Repeat Finding, if Applicable – Not a repeat finding. Recommendation – The Organization should revise its Procurement Policy to reflect the purchase types included in 2 CFR 200.320 and 2 CFR 180. Finance department staff should be trained on the revised policy and procedure with a system of internal controls developed to improve compliance.