Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Criteria The Health System has a policy whereby purchases shall comply with Uniform Guidance for Grants and Cooperative agreements, as established in 2 CFR 200.320 Methods of Procurement to be followed and they have adopted $10,000 as their micro-purchase threshold. 2 CFR 200.318 requires that documentation of the history of the procurement, the procurement method and rationale for the method selected, selection of contract type, basis for contractor selection, and basis for the contract price to be included in the procurement file. Additionally, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The Health System?s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition As part of the Research and Development cluster procurement testing of new purchases greater than $10,000 there were 4 transactions selected for testing out of a population of 21 transactions totaling $481,000. We noted two transactions of $69,500 and $12,000 where there was no documentation of the vendor justification, but were determined to be sole source. Management was able to provide us with an understanding of why the vendor was selected; however, this sole source justification was not documented in the procurement files. Additionally, as part of the testing over compliance with the Health System?s suspension and debarment verification policy, we noted one vendor with expenditures of $1,400 where the suspension and debarment verification was not performed in advance of paying the related invoice. We received evidence of the suspension and debarment verification completed after invoice payment, where no exclusions were identified. Cause While the procurement policy outlines the procedures to be followed for federal purchases, there is no formal review to ensure all federal documentation requirements related to purchases above the micropurchase threshold have been included in the procurement files. Additionally, there is no formal review to ensure that suspension and debarment verifications have been completed for all vendors prior to invoice payment. Effect The lack of adherence to established policies for bidding documentation and sole source justification and a formal process for review could result in competition being inappropriately limited. The lack adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Health System formalize the documentation and review required for procurements over the micro-purchase threshold, including review of multiple vendor quotations or sole source justification documentation prior to the purchase being made. Additionally, the Health System should ensure that timely suspension and debarment verifications are completed in line with policy. Management?s View and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary of status of prior audit findings
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.
Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.
Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.
Finding: 2022-001 Repeat Finding: No Type: Significant Deficiency Programs Affected AL 84.425 ? U.S. Department of Education ? Education Stabilization Fund Criteria Procurement standards for the College are identified in 2 CFR Section 200.318 through 200.327. To effectively communicate and maintain compliance with the regulations the College should have formal written procedures that address the compliance requirements for procurement. Effect: Without a properly documented policy the College lacks the effective method to communicate procedures to comply with the procurement standard. Condition The College does not have a formal written procurement policy that addresses the specific requirements of 2 CFR Section 200.318 through 200.327. Questioned Cost None Recommendation The College should formalize a policy for the procurements requirements. Views of Responsible Officials and Corrective Action Plan The College agrees with the finding.
Finding: 2022-001 Repeat Finding: No Type: Significant Deficiency Programs Affected AL 84.425 ? U.S. Department of Education ? Education Stabilization Fund Criteria Procurement standards for the College are identified in 2 CFR Section 200.318 through 200.327. To effectively communicate and maintain compliance with the regulations the College should have formal written procedures that address the compliance requirements for procurement. Effect: Without a properly documented policy the College lacks the effective method to communicate procedures to comply with the procurement standard. Condition The College does not have a formal written procurement policy that addresses the specific requirements of 2 CFR Section 200.318 through 200.327. Questioned Cost None Recommendation The College should formalize a policy for the procurements requirements. Views of Responsible Officials and Corrective Action Plan The College agrees with the finding.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY 2020/2021, SY 2021/2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states in part: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusion; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 for when informal procedures can be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for three of the five vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Suspension and Debarment Non-federal entities and contractors are subject to non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in Federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During fiscal years 2020-2021 and 2021-2022, the School Corporation entered into a covered transaction with Stanz Food Service, Inc.. Procedures were not performed to ensure that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in Federal assistance programs or activities. The lack of controls and noncompliance were systemic issues throughout the audit period. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that 3 quotes are obtained as required for small purchase method procurements and to ensure the vendors are not debarred or suspended. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Assistance Listing Numbers: 10.533, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 83-8010 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.318(i) states: ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Context: Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not follow procurement requirements for purchases of milk and dairy which fell under small purchase procedures. The School Corporation did not obtain price or rate quotes from an adequate number of qualified sources for the one vendor used for the purchase of milk and dairy during FY 2021. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.