Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024
Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023
Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024
Community Health Center Program – State Identifying No. 435.151301
Wisconsin Department of Health
Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024
Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023
Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318.
Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance.
Questioned Costs – None
Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals.
Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.
Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance.
Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.