As permitted by the West Virginia Department of Health, Health Facilities and Human Services’ (WVDHHFHS) State Opioid Response (SOR) General Operations Grant (G230821), Boone Memorial Hospital, Inc. (Hospital) acquired services through a local marketing and public relations agency that specialists i...
As permitted by the West Virginia Department of Health, Health Facilities and Human Services’ (WVDHHFHS) State Opioid Response (SOR) General Operations Grant (G230821), Boone Memorial Hospital, Inc. (Hospital) acquired services through a local marketing and public relations agency that specialists in healthcare marketing. The services provided, totaled $10,000, included a video production session arranged by the local marketing agency, but provided by a sub-contracting service provider and social media editing services that were completed directly by the local marketing agency. All services provided were included on a single invoice submitted by the marketing agency for ease of payment for the Hospital.
While we acknowledge the Hospital was not compliant with procurement regulations outlined by 2 CRF 200 Subpart D related to small purchase procedures, we believe the reported non-compliance is not material to the overall procurement associated with the above-mentioned grant. The engaged local healthcare marketing firm has provided services to the Hospital for several years. They also provide similar services to other hospitals throughout the region. The oppressed economic environment throughout the region limits the number of competitive vendors that provide healthcare specific marketing and public relations services throughout the area. Management believes that a healthcare focused service provider was the most appropriate solution for the services obtained and is confident that the developed relationship with the local service provider ensured competitive pricing. Also, since we utilize this agency for our external marketing services we believe that they gave us a reasonable and competitive price for the services provided, so we did not solicit bids from vendors that we have not previously utilized as we believe vendor pricing for a small one time project would be higher.
As a result of the noted commentary, the following corrective actions will be taken to prevent future non-compliance:
• Enhanced education around the Hospital’s established procurement procedures and the compliance requirements associated with the Uniform Guidance procurement regulations outlined in 2 CFR Part 200 Subpart D will be completed for individuals involved in the grants administration and individuals involved in the Hospital’s procurement process.
• For service greater than the micro purchase threshold, we will maintain contemporaneous formal written documentation for quotes, bids, or qualification for non-competitive proposal requirements, as applicable.
• When applicable, the Hospital will enhance internal controls and documentation to ensure supervisory review for compliance with federal procurement stands.
Completion Date: June 30, 2025