Finding Text
Finding Number: 2023-003
Finding Type: Federal award finding
Federal Assistance Listing No.: n/a
Program Name: R&D cluster
Federal Agency: Agency for Healthcare Research and Quality
Pass-Through Entity: n/a
Grant Number: 93-75Q80122C00002
Federal Award Year: 2023
Control Deficiency Type: Significant deficiency over compliance
Instance of Noncompliance: Yes
Compliance requirement: Procurement standards
Questions Costs: No
Repeat Finding: No
Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Princi-ples, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements require a non-federal agency to maintain records sufficient to detail the history of procurement, including rationale for the meth-od of procurement, selection of contract type, selection of contractor and the basis for the contract price.
Condition: The Foundation has established procurement procedures consistent with 2 CFR Part 200. Purchases over $25,000 must include documentation of the need for the purchase, the basis of the contractor selection and the price data. Purchases over $50,000, require three bids or a Sole Vendor Justification form if the services are to be obtained from one particular source. During our audit, we noted that the Foundation had entered into three con-tracts for professional services. Two of the contracts were over $25,000, and one was over $50,000. For these con-tracts, the Foundation was not able to provide the required documentation in accordance with the its established procurement policies.
Cause: Staff was not aware of the requirement for written procurement documentation consistent with the Founda-tion’s established procedures and lacked the knowledge and training related to the management of federal funds.
Effect: The Foundation did not fully comply with its established procurement standards.
Questioned Costs: None.
Audit Recommendation: Foundation’s management should ascertain that staff has the required knowledge and training to comply with the Foundation’s established procurement procedures and required documentation.
Management’s Response:
Explanation of disagreement with the audit finding: There is no disagreement with the audit finding.
Action taken in response to the finding: PVARF leadership communicated with PVARF staff the purchasing poli-cies and need for required documentation for purchases over $25,000 and over $50,000. Additionally, PVARF leadership communicated the need for the Sole Vendor Justification form if services are provided by one vendor. PVARF leadership staff also secured the required Sole Vendor Justification and Certification forms for the con-tracts missing documentation.
Action Plan: PVARF will continue to provide appropriate purchasing and procurement training. PVARF will fol-low established procedures for the required number of bids, need for purchase, contractor selection and price data and will secure justification and certification forms as part of its contracting processes.
Plan completion date for corrective action plan: June 30, 2024.