Finding Text
Criteria: Nonfederal entities other than States, including those operating Federal programs as
subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318
through 200.326. They must use their own documented procurement procedures, which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable Federal
statutes and the procurement requirements identified in 2 CFR Part 200.
Nonfederal entities other than States, including those operating Federal programs as subrecipients of
States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which
implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency
regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program
legislation; and the terms and conditions of the award.
Condition: During transactional testing, the following was noted:
• 93.441 – 4 out of 6 vendors reviewed did not have evidence of multiple competitive bids being
obtained.
Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or
debarred prior to conducting business.
• 93.441 – 4 out of 6 vendors reviewed did not have evidence or processes in place to check to ensure
vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were
suspended of debarred.
Context: The audit findings represent a systematic problem, see condition above.
Cause: There were ineffective controls in place during the period over procurement, along with lack of
management oversight.
Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their
policies by making sure bidding support is provided before the appropriate officials sign the Purchase
Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be
an unallowable cost.
Questioned Costs:
AL#: 93.441
Known: Procurement- $71,963.
Repeat Finding: Yes, 2022-007 and 2023-004.
Recommendation: We recommend the Clinic conduct training for staff and program managers to review
the Clinic’s procurement and suspension and debarment policies and procedures along with federal
regulations.
Views of Responsible Officials and Planned Corrective Action: The Clinic will review the procurement
standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply
with all required purchasing standards. All vendors will be required to submit and certify a statement
regarding debarment and suspension prior to contract award.