Finding Text
FINDING 2024-005
Procurement – Documentation
FINDING TYPE
Significant Deficiency in Internal Control over Compliance
AGENCY
U.S. Department of Health and Human Services
ALN
93.224 / 93.527 Health Center Cluster
CRITERIA
In accordance with 2 CFR 200.318(i), entities receiving federal funds are responsible for
maintaining records that contain sufficient detail of the history of each procurement
transaction. These records must include the rationale for the procurement method, contract
type selection, contractors selection or rejections, and the basis for the contract price.
CONDITION AND CONTEXT
We selected four procurements for testing. Out of these four, we noted one instance where
the documentation of the rationale behind the vendor selection was not available.
Management was able to explain to us why the vendor offered an appropriate mix of price
and value to the Federal program, but the documentation of the decision was not able to be
presented. Also, for one out of four tested items, a record of the initial debarment/suspension
check was not able to be produced. Management was able to show us a master vendor
database compliance screening that was run after this vendor had been selected. However,
documentation of the initial check was not available.
CAUSE
The staff involved with these procurement decisions did not have a consistent process for
maintaining documentation related to procurement decisions.
EFFECT OR POTENTIAL EFFECT
Without consistent documentation, there is a risk that procurement decisions will not be in
compliance with the procurement requirements of the Uniform Guidance.
REPEAT FINDING
No.
RECOMMENDATION
We recommend that the organization reinforce to all personnel involved in procurement the
importance of maintaining the required documentation for procurement decisions.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION
See attached corrective action plan.
Questioned Costs
None.