Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200 and management's internal policies and procedures related to procurement, suspension, and debarment.
Planned Corrective Action: Management agrees with the improvement ...
Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200 and management's internal policies and procedures related to procurement, suspension, and debarment.
Planned Corrective Action: Management agrees with the improvement of documentation of procurement, suspension, and debarment. As noted below, purchasing policies are being followed, but were not always formally documented. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses.
The findings noted three procurement contracts that were more than $50,000 that did not properly document the rationale for selection and/or sole procurement. The first contract was a single source provider for the replacement of thermostats. Other heating and air conditioning vendors would not handle the replacement of the thermostats as it was not their equipment. There was also a preventative maintenance agreement with the vendor: Phoenix Heating and Air. We will document the use of a single source contractor as allowed in our purchasing policies. We did follow the other control procedures regarding contract approvals, obtaining Certificates of Insurance and verifying completion of the work.
The second contract was related to our website and marketing company: Brand Vibe. We did an open bid process, two years earlier, and renewed the contract without a formal bid process. As mentioned above, we did follow the proper approval process and verified the work was completed. The total of this contract for FY 2024 was $74,665, however only $3,600 was charged against the federal grant. Going forward, we will document the rationale for renewing the contract.
The third contract was for a bi-lingual APN, with a Psych. Certificate, who was a former employee. She wanted to work part-time, and we switched her to a 1099 employee. With her experience and work record, we allowed her to transition to a part-time contractor. Our experience finding bi-lingual providers has been difficult, and the agency costs are almost double the cost paid for this contractor. The amount charged to the Trauma-Informed Centers of Care was $47,769. In the future, we will formally document the selection and use of this contractor. As noted, we did have a formal contract. and all providers are approved by the Board.
Management will make necessary revisions to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200.
Specifically, management will ensure the history of procurement - whether obtained through quotes, formal competitive bids, or through non-competitive means – is documented, including evidence that a cost-price analysis was performed for all purchases in excess of the simplified acquisition threshold. Additionally, before entering a covered transaction with third parties, management will have a form completed by the outside parties stating they are not suspended or debarred from engaging in federal activity before entering a covered transaction. This form will be retained, and we will check and document Sam.gov, excluded parties listing.
Contact person responsible for corrective action: Karen L. Williams, Chief Financial Officer
Anticipated Completion Date: 06/30/2025