Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors...
Corrective Action Plan (CAP) Finding 2025-001 – Procurement Documentation Program: FAN 93.676 Unaccompanied Alien Children Program Finding Type: Significant Deficiency and Non-Compliance Agency: U.S. Department of Health & Human Services Management Response SWK respectfully acknowledges the auditors' concerns regarding the retention and availability of historical procurement documentation. However, SWK notes that this finding relates primarily to documentation retention and retrieval rather than a failure to perform procurement activities or suspension and debarment verification. The primary issue resulted from the termination of the Unaccompanied Alien Children (UAC) Program during Fiscal Year 2025, which led to significant organizational downsizing, including the elimination of the Procurement Department. Historical procurement, solicitation, and bid documentation had been maintained within a procurement software platform administered by that department. Following program closure and the departure of procurement personnel, the software platform was decommissioned, resulting in certain historical procurement records no longer being readily accessible during the audit. SWK did, however, provide evidence that vendors selected for procurement actions were screened for suspension and debarment in accordance with federal requirements. Additionally, two of the six contracts exceeding the simplified acquisition threshold represented renewals of previously procured contracts; however, complete historical bid files could not be retrieved for audit review. SWK further notes that as of the date of this corrective action plan: • The UAC Program has been terminated. • SWK no longer maintains a dedicated Procurement Department. • SWK has no active federal procurement contracts over $250,000 requiring formal solicitation procedures. • No questioned costs were identified by the auditors. • The auditors concluded that services and goods purchased under the reviewed contracts were allowable and supported program operations. Corrective Actions Although the circumstances surrounding this finding relate to historical records associated with a discontinued program, SWK has implemented the following actions to strengthen document retention and procurement oversight for any future federally funded procurements: 1. Centralized Procurement Record Retention SWK has established a requirement that all procurement-related documentation, including solicitations, bid responses, evaluations, vendor selection justifications, contract approvals, and suspension/debarment verifications, be maintained in a centralized electronic repository controlled by Finance and Administration, rather than an individual department or software administrator. 2. Procurement Documentation Checklist SWK will continue to utilize a standardized procurement checklist for any future procurement transactions subject to federal procurement requirements. The checklist will ensure required documentation is retained and readily accessible for monitoring or audit purposes. 3. Enhanced Document Archiving Procedures Prior to the discontinuation of any program, department, or software platform, SWK will perform a records-retention review to ensure all procurement and contract documentation subject to federal record retention requirements is archived and preserved. 4. Management Oversight The Chief Administrative Officer will be responsible for periodic reviews of procurement files to verify that required documentation is complete and retained in accordance with federal and organizational requirements. 5. Future Procurements SWK will review and update its documented procurement procedures to conform to applicable federal statutes, the procurement requirements identified in 2 CFR Part 200, and the new federal procurement thresholds as of October 1, 2025. Further, SWK will institute a centralized purchasing function under Finance and Administration to facilitate the review of procurements to ensure compliance with both 2 CFR Part 200 and the terms and conditions of awards. This function will ensure the enforcement of the procedures mentioned above by: - Conducting vetted vendor onboarding and ongoing management via periodic reviews to verify that non-federal entities, contracts, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federal programs - Obtaining appropriate documentation of multiple vendor quotes and/or sole source justification for small purchases greater than the micro-purchase threshold, but below the simplified acquisition threshold - Managing, following, and documenting the simplified acquisition procedures for purchases greater than or equal to the simplified acquisition threshold Expected Completion Date: In process and to be completed by December 31, 2026 Ongoing monitoring and compliance reviews will continue for any future procurement activities. Status Corrective action substantially implemented. Upon review of current FY2026 purchases and due to the closure of the UAC Program, the risk associated with this finding has been significantly reduced. The corrective actions above are designed to ensure appropriate documentation retention and compliance should future federally funded procurement activities occur. Responsible Officials: Chief Administrative Officer, Marisol Cervera