Finding Text
Compliance Requirement: Procurement and Suspension and Debarment
Information on the Major Federal Program:
Federal agency: U.S. Department of Health and Human Services
Pass-through entity: Council of Medical Specialty Societies
Assistance listing number: 93.083
Assistance listing name: COVID-19 Prevention of Disease, Disability, and Death through Immunization and Control of Respiratory and Related Diseases
Award number: 1NH231P922656-01-00
Award name: Improving adult immunization rates for COVID-19, influenza and routine adult vaccination through partnerships with medical subspecialty societies
Award year: 9/30/2021 – 9/30/2026
Criteria – The Uniform Guidance in 2 CFR 200.320 sets forth the standards for procurement by non-federal entities. Specifically, for small purchases, which are defined as those that exceed the micro-purchase threshold but do 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. The entity must maintain records sufficient to detail the history of the procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, when the internal procurement thresholds set by the non-federal entity are lower than Uniform Guidance mandated thresholds, the more stringent or lower thresholds are to be followed.
Condition – The College's federal procurement manual defines small purchases as acquisition of goods and services that exceed $3,000 but are under the simplified acquisition threshold of $150,000 in a fiscal year. It requires that for such purchases, the College must obtain current price and rate quotations from at least three or more adequate and qualified vendors/suppliers. However, for one procurement sample out of six tested, quotations were not obtained from at least three vendors and procurement was made based on prior experience with the chosen vendor.
Cause – The College failed to comply with its internal control policies and procedures with regards to federal procurement, resulting in the College making a small purchase without ensuring that the procurement process was competitive and the best possible price was obtained for the purchase.
Questioned Costs – There are $20,000 of known questioned costs related to the items presented in the condition above.
Context – This is a condition identified per review of the College’s compliance with its federal procurement manual and requirements of procurement, suspension and debarment of the Uniform Guidance using a non-statistical sample. The prevalence of this finding is detailed in the condition section above.
Effect – Failure to comply with the College’s internal procurement policies and with requirements under Uniform Guidance increases the risk of uncompetitive pricing and potential misuse of federal funds.
Repeat Finding – This is not a repeat finding.
Recommendation – The College should provide training to its procurement personnel on the requirements of the College’s own federal procurement manual as well as on the Uniform Guidance procurement requirements. Additionally, the College should implement a review process to ensure that all small purchases comply with the requirement to obtain price or rate quotations from an adequate number of qualified sources.
Views of Responsible Officials – Management acknowledges the finding and recommendation presented. Management will enhance federal grant personnel skills through re-training on procurement policies and Uniform Guidance. The Privacy and Research Compliance Officer will ensure quotes are obtained from qualified sources, and the Legal Department will draft contracts only after confirming compliance. These steps ensure informed purchasing and responsible use of federal funds.