Finding Text
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance
CFDA 93.676 - Unaccompanied Children Program
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services
Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor.
Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements.
Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations.
Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods.
Questioned Costs: Not applicable
Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk.
Identification As A Repeat Finding: N/A
Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties.
Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.